Scoping for Battery Energy Storage Systems Programmatic Environmental Impact Statement
To the Department of Ecology, Clean Energy Coordination:
My name is Conner and I live at 7207 St Andrews Ln SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-ion b...↓attery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My children attend school near a proposed stand-alone BESS site, at Cascade View. I am a CFP, and I offer this comment with that professional background.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Conner
7207 St Andrews Ln SE↓
My name is Conner and I live at 7207 St Andrews Ln SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-ion b...↓attery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My children attend school near a proposed stand-alone BESS site, at Cascade View. I am a CFP, and I offer this comment with that professional background.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Conner
7207 St Andrews Ln SE↓
No attachments
Please see the attached letter from City of Bonney Lake Mayor Terry Carter.
Attachments:
To the Department of Ecology, Clean Energy Coordination:
My name is Nikki Bragg, and I live at 36427 SE Woody Creek Lane in Snoqualmie, Washington. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement (PEIS) fo...↓r stand alone, utility scale, lithium-ion battery energy storage system (BESS) facilities in Washington (Publication 26-06-017).
I am submitting this comment because a stand alone BESS facility is proposed near my home. Because the Department of Ecology has indicated that future project level environmental reviews will tier to this PEIS, I believe it is especially important that the PEIS fully address the concerns of communities that may ultimately live alongside these facilities.
The Department of Ecology has asked for input on several questions as part of the scoping process. My comments below address Questions 2, 3, and 4.
Q2 · Geographic Scope — Where the Study Assumes Batteries Will Go
I believe the geographic scope of this study needs to look beyond where a BESS facility can physically be built and consider where it can be safely located in relation to the people and communities around it.
Proximity to existing infrastructure should not be treated as a stand in for a safe or suitable site. Being near a substation, for example, should not automatically make an area "suitable." The Department of Ecology study should define suitable areas based on the conditions that affect the safety of the people who live there, not simply on whether a facility could be connected to the grid.
Conditions such as those found in the Snoqualmie Valley should be part of this analysis. This is the opportunity to shape the study area before the Department of Ecology establishes the assumptions that will guide later project level reviews. The geographic assumptions should therefore screen for locations with private wells, floodplains, earthquake faults, neighborhoods with limited access, and other conditions that could significantly affect the consequences of a BESS incident.
Wildfire exposure and local fire district capacity also need to be part of the geographic analysis. The Department of Ecology's own earlier studies identified wildfire risk associated with "new ignition sources in remote locations with limited response capabilities." That concern is particularly important when considering communities where emergency response resources may already be limited.
The Department of Ecology has committed to hearing from local communities. I believe that means taking seriously what residents know about the places where we live, including the characteristics that may not be apparent from a statewide infrastructure map.
For these reasons, I ask that the PEIS geographic scope assumptions explicitly account for:
1. Proximity to homes, schools, and hospitals;
2. Wildland and urban interface and wildfire prone areas;
3. Seismic hazard zones and floodplains;
4. Areas dependent on private wells; and
5. Communities with limited evacuation routes.
Most importantly, proximity to existing infrastructure should not be treated as a proxy for suitability.
Q3 · Impacts to Analyze — The Harms the Study Needs to Examine
I am particularly concerned that the PEIS fully examine what a battery fire could mean for the people living nearby, not only for firefighters responding to the incident.
The scoping document acknowledges that toxic gases released from damaged batteries can harm firefighters' skin and lungs. However, nearby residents are also potentially exposed, and unlike firefighters, they do not have protective equipment, cannot hermetically seal homes or businesses, or necessarily have the ability to leave immediately.
The study should therefore model what battery fire smoke means for the people living in the surrounding community. This should include dispersion modeling under conditions such as nighttime inversions and valley geography, where smoke and hazardous gases may not disperse as they would in an open or well ventilated setting.
Noise is another impact that deserves more careful consideration. The study should measure nighttime noise at the nearest residence, rather than simply at a property or facility boundary. The Department of Ecology's earlier studies found that noise from these facilities can reach 1,000 feet in quiet rural areas. The people and pets experiencing that noise are the residents who live nearby, so the analysis should reflect that reality.
The PEIS should also examine what a multi-day battery fire could demand from local fire, HazMat, hospital, and evacuation resources. This is particularly important for smaller rural fire districts. The Department of Ecology has previously been unable to say whether the burden placed on small rural fire districts can always be addressed, and that uncertainty should not be left for individual communities to discover only after a project is proposed.
I would like to see the study thoroughly examine the direct, indirect, and cumulative effects of:
1. Smoke and hazardous gases settling or being trapped in valleys;
2. Fire suppression runoff reaching groundwater, private wells, and streams;
3. Multiple BESS facilities being located along the same stretch of the electrical grid;
4. The ability of nearby residents to evacuate without being exposed to dangerous concentrations of toxic gas; and
5. The ability of local emergency services to respond to a prolonged incident.
The study should properly model whether neighbors can safely and effectively evacuate without breathing dangerous levels of toxic gas in locations such as valleys that can trap air, consistent with what the applicable fire safety requirements are intended to protect against.
I ask that the PEIS specifically analyze, for stand alone facilities:
1. Thermal runaway fires and hazardous gas emissions, including hydrogen fluoride, with dispersion modeling for inversion prone valleys;
2. Contaminated fire suppression water and its potential path to groundwater, private wells, and fish bearing streams;
3. Multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity;
4. Continuous nighttime noise from cooling systems and inverters at distances beyond 1,000 feet; and
5. Seismic performance of container based installations in mapped fault zones.
Q4 · Mitigation — The Steps the Department of Ecology Should Require to Reduce Harm
I also believe the PEIS needs to be specific enough that local governments and communities have meaningful standards to rely on when an actual project comes before them. My county may ultimately depend on the findings and mitigation measures in this PEIS when reviewing a proposed facility, so the recommendations need to be concrete and enforceable rather than simply general guidance.
The siting and design considerations the Department of Ecology develops for project proponents should include minimum distances from homes, schools, hospitals, and drinking water wells that are demonstrated to provide meaningful protection for surrounding communities.
The study should also recommend that large scale fire testing be required for every facility, regardless of whether Washington has adopted the newest applicable code, particularly because the Department of Ecology itself credits this testing with reducing risk.
Where a potential impact cannot realistically be mitigated, for example where a fire could exceed the containment capabilities of a small rural fire district, the PEIS should say so plainly and identify that impact as unavoidable rather than leaving the issue for residents and local decision makers to determine on a project-by-project basis.
The study should also clearly state that local governments may require protections stronger than state minimum standards. State standards should serve as a floor, not a ceiling, particularly when local conditions create risks that statewide minimums may not adequately address.
In addition, I ask that the PEIS recommend developer funded monitoring, cleanup guarantees, and decommissioning bonds, consistent with the financial and environmental protections that state rules already require for other energy facilities.
Specifically, I ask that the PEIS identify concrete mitigation measures, including:
1. Minimum setbacks from homes, schools, hospitals, and drinking water wells;
2. Large scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855, regardless of state adoption status;
3. Funded emergency response plans, training, and equipment for local fire districts before a facility begins operation;
4. Containment and disposal plans for contaminated fire suppression water;
5. Enforceable nighttime noise limits measured at the nearest residence; and
6. Decommissioning and financial assurance requirements.
The Impact on My Household and Community
This issue is personal for my household. I live near a location where a stand alone BESS facility is proposed, so these are not abstract concerns to me. They are questions about the safety and quality of life of the community where my family lives.
My household depends on the Snoqualmie Parkway, which is also the emergency route for everyone living along it. The ability of residents to evacuate safely, and the ability of emergency responders to reach us, are therefore very real considerations when evaluating the suitability of a proposed facility.
Because the Department of Ecology itself states that stand alone facilities "could be sited in a variety of locations," including near cities, I do not believe the PEIS should make assumptions that these facilities will generally be located far away from people.
I respectfully ask the Department of Ecology to treat proximity to residents as a defining condition of the analysis. Communities should not have to wait until a project level review happens to discover whether the characteristics of their particular neighborhood create risks that were not adequately considered at the programmatic level.
I also ask that the Draft PEIS clearly identify which impacts cannot be mitigated below significance. The public and local lead agencies should not be left to guess about the remaining risks or whether proposed mitigation is actually sufficient.
Thank you for taking the time to consider my comments and for including them in the scoping record. Our community is following this PEIS closely, and I intend to continue participating in the Draft PEIS comment period.
Sincerely,
Nikki Bragg
36427 SE Woody Creek Lane
Snoqualmie, WA 98065↓
My name is Nikki Bragg, and I live at 36427 SE Woody Creek Lane in Snoqualmie, Washington. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement (PEIS) fo...↓r stand alone, utility scale, lithium-ion battery energy storage system (BESS) facilities in Washington (Publication 26-06-017).
I am submitting this comment because a stand alone BESS facility is proposed near my home. Because the Department of Ecology has indicated that future project level environmental reviews will tier to this PEIS, I believe it is especially important that the PEIS fully address the concerns of communities that may ultimately live alongside these facilities.
The Department of Ecology has asked for input on several questions as part of the scoping process. My comments below address Questions 2, 3, and 4.
Q2 · Geographic Scope — Where the Study Assumes Batteries Will Go
I believe the geographic scope of this study needs to look beyond where a BESS facility can physically be built and consider where it can be safely located in relation to the people and communities around it.
Proximity to existing infrastructure should not be treated as a stand in for a safe or suitable site. Being near a substation, for example, should not automatically make an area "suitable." The Department of Ecology study should define suitable areas based on the conditions that affect the safety of the people who live there, not simply on whether a facility could be connected to the grid.
Conditions such as those found in the Snoqualmie Valley should be part of this analysis. This is the opportunity to shape the study area before the Department of Ecology establishes the assumptions that will guide later project level reviews. The geographic assumptions should therefore screen for locations with private wells, floodplains, earthquake faults, neighborhoods with limited access, and other conditions that could significantly affect the consequences of a BESS incident.
Wildfire exposure and local fire district capacity also need to be part of the geographic analysis. The Department of Ecology's own earlier studies identified wildfire risk associated with "new ignition sources in remote locations with limited response capabilities." That concern is particularly important when considering communities where emergency response resources may already be limited.
The Department of Ecology has committed to hearing from local communities. I believe that means taking seriously what residents know about the places where we live, including the characteristics that may not be apparent from a statewide infrastructure map.
For these reasons, I ask that the PEIS geographic scope assumptions explicitly account for:
1. Proximity to homes, schools, and hospitals;
2. Wildland and urban interface and wildfire prone areas;
3. Seismic hazard zones and floodplains;
4. Areas dependent on private wells; and
5. Communities with limited evacuation routes.
Most importantly, proximity to existing infrastructure should not be treated as a proxy for suitability.
Q3 · Impacts to Analyze — The Harms the Study Needs to Examine
I am particularly concerned that the PEIS fully examine what a battery fire could mean for the people living nearby, not only for firefighters responding to the incident.
The scoping document acknowledges that toxic gases released from damaged batteries can harm firefighters' skin and lungs. However, nearby residents are also potentially exposed, and unlike firefighters, they do not have protective equipment, cannot hermetically seal homes or businesses, or necessarily have the ability to leave immediately.
The study should therefore model what battery fire smoke means for the people living in the surrounding community. This should include dispersion modeling under conditions such as nighttime inversions and valley geography, where smoke and hazardous gases may not disperse as they would in an open or well ventilated setting.
Noise is another impact that deserves more careful consideration. The study should measure nighttime noise at the nearest residence, rather than simply at a property or facility boundary. The Department of Ecology's earlier studies found that noise from these facilities can reach 1,000 feet in quiet rural areas. The people and pets experiencing that noise are the residents who live nearby, so the analysis should reflect that reality.
The PEIS should also examine what a multi-day battery fire could demand from local fire, HazMat, hospital, and evacuation resources. This is particularly important for smaller rural fire districts. The Department of Ecology has previously been unable to say whether the burden placed on small rural fire districts can always be addressed, and that uncertainty should not be left for individual communities to discover only after a project is proposed.
I would like to see the study thoroughly examine the direct, indirect, and cumulative effects of:
1. Smoke and hazardous gases settling or being trapped in valleys;
2. Fire suppression runoff reaching groundwater, private wells, and streams;
3. Multiple BESS facilities being located along the same stretch of the electrical grid;
4. The ability of nearby residents to evacuate without being exposed to dangerous concentrations of toxic gas; and
5. The ability of local emergency services to respond to a prolonged incident.
The study should properly model whether neighbors can safely and effectively evacuate without breathing dangerous levels of toxic gas in locations such as valleys that can trap air, consistent with what the applicable fire safety requirements are intended to protect against.
I ask that the PEIS specifically analyze, for stand alone facilities:
1. Thermal runaway fires and hazardous gas emissions, including hydrogen fluoride, with dispersion modeling for inversion prone valleys;
2. Contaminated fire suppression water and its potential path to groundwater, private wells, and fish bearing streams;
3. Multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity;
4. Continuous nighttime noise from cooling systems and inverters at distances beyond 1,000 feet; and
5. Seismic performance of container based installations in mapped fault zones.
Q4 · Mitigation — The Steps the Department of Ecology Should Require to Reduce Harm
I also believe the PEIS needs to be specific enough that local governments and communities have meaningful standards to rely on when an actual project comes before them. My county may ultimately depend on the findings and mitigation measures in this PEIS when reviewing a proposed facility, so the recommendations need to be concrete and enforceable rather than simply general guidance.
The siting and design considerations the Department of Ecology develops for project proponents should include minimum distances from homes, schools, hospitals, and drinking water wells that are demonstrated to provide meaningful protection for surrounding communities.
The study should also recommend that large scale fire testing be required for every facility, regardless of whether Washington has adopted the newest applicable code, particularly because the Department of Ecology itself credits this testing with reducing risk.
Where a potential impact cannot realistically be mitigated, for example where a fire could exceed the containment capabilities of a small rural fire district, the PEIS should say so plainly and identify that impact as unavoidable rather than leaving the issue for residents and local decision makers to determine on a project-by-project basis.
The study should also clearly state that local governments may require protections stronger than state minimum standards. State standards should serve as a floor, not a ceiling, particularly when local conditions create risks that statewide minimums may not adequately address.
In addition, I ask that the PEIS recommend developer funded monitoring, cleanup guarantees, and decommissioning bonds, consistent with the financial and environmental protections that state rules already require for other energy facilities.
Specifically, I ask that the PEIS identify concrete mitigation measures, including:
1. Minimum setbacks from homes, schools, hospitals, and drinking water wells;
2. Large scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855, regardless of state adoption status;
3. Funded emergency response plans, training, and equipment for local fire districts before a facility begins operation;
4. Containment and disposal plans for contaminated fire suppression water;
5. Enforceable nighttime noise limits measured at the nearest residence; and
6. Decommissioning and financial assurance requirements.
The Impact on My Household and Community
This issue is personal for my household. I live near a location where a stand alone BESS facility is proposed, so these are not abstract concerns to me. They are questions about the safety and quality of life of the community where my family lives.
My household depends on the Snoqualmie Parkway, which is also the emergency route for everyone living along it. The ability of residents to evacuate safely, and the ability of emergency responders to reach us, are therefore very real considerations when evaluating the suitability of a proposed facility.
Because the Department of Ecology itself states that stand alone facilities "could be sited in a variety of locations," including near cities, I do not believe the PEIS should make assumptions that these facilities will generally be located far away from people.
I respectfully ask the Department of Ecology to treat proximity to residents as a defining condition of the analysis. Communities should not have to wait until a project level review happens to discover whether the characteristics of their particular neighborhood create risks that were not adequately considered at the programmatic level.
I also ask that the Draft PEIS clearly identify which impacts cannot be mitigated below significance. The public and local lead agencies should not be left to guess about the remaining risks or whether proposed mitigation is actually sufficient.
Thank you for taking the time to consider my comments and for including them in the scoping record. Our community is following this PEIS closely, and I intend to continue participating in the Draft PEIS comment period.
Sincerely,
Nikki Bragg
36427 SE Woody Creek Lane
Snoqualmie, WA 98065↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Jade Angster and I live at 901 SE Cedar Falls Way, North Bend, WA 98045. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone,...↓ utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live downstream or downwind of a proposed stand-alone BESS site, the BESS Snoqualmie Valley project, in the same air basin, fire district, and hospital service area. I am a Geologist, and I offer this comment with that professional background.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Jade Angster
901 SE Cedar Falls Way, North Bend, WA 98045↓
My name is Jade Angster and I live at 901 SE Cedar Falls Way, North Bend, WA 98045. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone,...↓ utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live downstream or downwind of a proposed stand-alone BESS site, the BESS Snoqualmie Valley project, in the same air basin, fire district, and hospital service area. I am a Geologist, and I offer this comment with that professional background.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Jade Angster
901 SE Cedar Falls Way, North Bend, WA 98045↓
No attachments
I am concerned that you treat proximity to residents as a defining condition and do not assume that proposals will address this properly. Washington has a lot of remote land that could be used for these facilities without threat to our residents. Tha...↓nk you↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Lacey Labrum and I live at 34019 SE VAughan street. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithi...↓um-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My children attend school near a proposed stand-alone BESS site, at Timber Ridge Elementary. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Lacey Labrum
34019 SE VAughan street↓
My name is Lacey Labrum and I live at 34019 SE VAughan street. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithi...↓um-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My children attend school near a proposed stand-alone BESS site, at Timber Ridge Elementary. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Lacey Labrum
34019 SE VAughan street↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Rosalyn Vick and I live at 7030 Allman Ave SE, Snoqualmie WA 98065, United States. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for st...↓and-alone, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Theres plenty of options available that are not near schools, residential dwellings, daycare. This has a major risk to immediate community. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
I want the study to take into serious consideration real examples of other sites and harm done. The impact on the surrounding community with long lasting effects I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Snoqualmie BESS project. My children attend school near a proposed stand-alone BESS site. My household depends on I-90, sr-18, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Rosalyn Vick
7030 Allman Ave SE, Snoqualmie WA 98065, United States↓
My name is Rosalyn Vick and I live at 7030 Allman Ave SE, Snoqualmie WA 98065, United States. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for st...↓and-alone, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Theres plenty of options available that are not near schools, residential dwellings, daycare. This has a major risk to immediate community. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
I want the study to take into serious consideration real examples of other sites and harm done. The impact on the surrounding community with long lasting effects I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Snoqualmie BESS project. My children attend school near a proposed stand-alone BESS site. My household depends on I-90, sr-18, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Rosalyn Vick
7030 Allman Ave SE, Snoqualmie WA 98065, United States↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Jennifer Good and I live at 39664 SE Spruce Street, Snoqualmie WA98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, ...↓utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." Our parks and neighborhoods have substations nearby by; however the damage a battery fire could cause to those homes, parks and businesses is a reason why these areas should be protected. Battery sites should be located far away from those.
The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. The study's geographic assumptions should screen out places with private wells, floodplains, earthquake faults, and neighborhoods with one road out, because site details will be left to later reviews. Earthquakes and floods could impact the integrity of the batteries, making these locations unsafe. These locations should not even be a consideration for storage. Private wells could also be impacted if there were a leak or chemicals were used to put out a fire. Locations near private wells shouldn't be allowed I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Jennifer Good
39664 SE Spruce Street, Snoqualmie WA98065↓
My name is Jennifer Good and I live at 39664 SE Spruce Street, Snoqualmie WA98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, ...↓utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." Our parks and neighborhoods have substations nearby by; however the damage a battery fire could cause to those homes, parks and businesses is a reason why these areas should be protected. Battery sites should be located far away from those.
The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. The study's geographic assumptions should screen out places with private wells, floodplains, earthquake faults, and neighborhoods with one road out, because site details will be left to later reviews. Earthquakes and floods could impact the integrity of the batteries, making these locations unsafe. These locations should not even be a consideration for storage. Private wells could also be impacted if there were a leak or chemicals were used to put out a fire. Locations near private wells shouldn't be allowed I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Jennifer Good
39664 SE Spruce Street, Snoqualmie WA98065↓
No attachments
RE: Formal Scoping Comments – PEIS for Battery Energy Storage Systems (BESS)
To the Clean Energy Coordination Team/Washington State Department of Ecology
Please accept these formal scoping comments regarding the development of the statewide BESS PE...↓IS siting rules and code frameworks must not rely on the flawed precedent of municipal DNS for nonproject actions. As documented in municipal SEPA reviews, nonproject zoning and code updates directly dictate the siting, scale, and long-term prevalence of volatile infrastructure across Washington. Characterizing these updates as nonproject actions to evade strict impact reviews creates profound analytical gaps that violate SEPA.
To ensure future project-level reviews across Washington are legally defensible and supported by substantial evidence, the Department of Ecology must utilize this PEIS to mandate a comprehensive SEPA review that explicitly rejects generalized industry claims and incorporates the following 15 core structural, technical, and data-reporting constraints:
1. Rejection of Presumed Future Regulatory Compliance
• Analysis Requested: The PEIS must reject any code frameworks that rely on the assumption that compliance with federal, state, and local regulations is "presumed" and that noncompliance can simply be managed by post-approval enforcement. Reliance on WAC 51-54A-1207 and NFPA 855 focuses strictly on isolated system design and immediate fire containment; it completely fails to evaluate the external environmental consequences of a facility-wide BESS failure, including toxic atmospheric migration, environmental deposition, and off-site human exposure. Presuming compliance with codes that do not evaluate these pathways does not substitute for actual environmental analysis.
2. Distinction Between Fire Behavior Containment and Acceptance of Impact
• Analysis Requested: The PEIS must recognize that mandatory large-scale fire testing (such as UL 9540A frameworks) evaluates whether a fire can be physically contained—not whether the environmental consequences of that fire are acceptable. The existing code framework permits systems to vent immense columns of hazardous gas, allows active fires to burn uncontrollably under "controlled burn" strategies, and manages thermal events through containment rather than prevention. Testing standards do not evaluate toxic gas generation, emission durations, or off-site transport and environmental deposition. Siting rules must address whether the external impacts of a managed burn are acceptable at the proposed location.
3. Inclusion of Failure-Related Emissions, Venting, and Plume Behavior
• Analysis Requested: Siting reviews must mandate site-specific atmospheric plume modeling and dispersion analysis. Siting checklists routinely omit emissions associated with BESS failure events, focusing exclusively on normal operations or construction dust. Because modern lithium-ion and Lithium Iron Phosphate (LFP) installations are structurally engineered to vent highly toxic gases under thermal runaway and failure conditions, the PEIS must mandate consequence modeling for the atmospheric transport and downwind fallout of these anticipated, catastrophic system behaviors to protect homes, schools, and transit corridors.
4. Prohibition of Post-Approval Hazard Mitigation Analysis (HMA) Deferral
• Analysis Requested: The PEIS must explicitly prohibit the "improper deferral" trap of approving project sites or municipal codes before critical safety reviews occur. Siting frameworks must require that the Hazard Mitigation Analysis (HMA) and site-specific Emergency Response Plans be completed, publicly disclosed, and formally evaluated prior to conditional land-use authorization. Allowing developers to complete core safety and risk evaluations post-approval forces decision-makers to conduct environmental reviews without knowing the actual system-specific risk profile, rendering the resulting safety determinations arbitrary and capricious.
5. Comprehensive Evaluation of Compound and Cascading Multi-Unit Failures
• Analysis Requested: Siting and risk reviews must model compound, real-world failure states rather than discrete, single failure modes. Documented battery storage failures demonstrate that modern incidents routinely involve cascading multi-unit propagation, violent chemical interactions between fire suppression systems and thermal runaway cells, and extended-duration events characterized by toxic off-gassing and sudden re-ignition weeks after initial containment.
6. Resolution of Ambiguity Between "Normal" and "Abnormal" States
• Analysis Requested: The PEIS must establish strict, non-ambiguous definitions for operational states. Relying on code frameworks that exempt standard operating or idle states from strict safety buffers creates severe vulnerabilities. Empirical data proves that catastrophic real-world battery failures frequently initiate during standard operating states, including idle and standby conditions, meaning failure pathways must be evaluated across all lifecycle states.
7. Evaluation of Passive Containment and Controlled Burn Consequences
• Analysis Requested: Siting codes must explicitly evaluate the environmental trade-offs of active versus passive fire management. Current code provisions do not mandate active fire suppression systems, allowing developers to deploy designs relying entirely on passive containment or controlled burns. The PEIS must model the severe environmental consequences of these design choices, specifically analyzing the extreme increase in fire durations and the immense cumulative volume of unmitigated toxic emissions released into the atmosphere during a prolonged passive burn.
8. Water and Groundwater Contamination Analysis Under Failure Conditions
• Analysis Requested: Siting rules must mandate self-contained, impervious secondary engineering containment basins and automated containment valves. Standard stormwater regulations are structurally incapable of handling the toxic byproducts of a battery disaster. When emergency responders apply millions of gallons of water to cool a burning installation, the resulting runoff carries heavy metals and corrosive hydrofluoric acid. Siting reviews must evaluate the volume and chemical composition of this contaminated runoff, its transport through local soils, and its long-term impact on critical groundwater tables and salmon-bearing aquatic ecosystems.
9. Internal Consistency and Regional Burden in Emergency Response Analysis
• Analysis Requested: Siting frameworks must eliminate the internal inconsistency of claiming a BESS project will not generate a demand for special emergency services while simultaneously acknowledging that BESS failures must be treated as complex, multi-agency hazardous materials incidents. The PEIS must model the real-world operational strains of a BESS failure, documenting how a single localized fire requires specialized regional Hazmat capabilities, specialized PPE, and the prolonged on-site deployment of local fire district resources to monitor for sudden re-ignition.
10. Meaningful Pre-Approval Evaluation of Critical Areas
• Analysis Requested: Siting maps must actively restrict utility-scale battery installations from being placed within sensitive environmental features. Deferring to future project-level compliance does not fulfill SEPA's mandate to protect critical areas. The PEIS must evaluate whether broad siting ordinances adequately shield Critical Aquifer Recharge Areas (CARAs), geologically hazardous zones, wetlands, and sensitive wildlife habitats from toxic fallout before any project boundaries are established.
11. Siting Boundaries, Judicial Limits, and More Protective Alternatives
• The Sumner/Auburn Precedents: Siting rules must formally adopt more protective regulatory choices, recognizing that the severe environmental impacts of battery infrastructure are entirely dependent on the stringency of the adopted framework. The PEIS must look to existing Washington municipal precedents, specifically City of Sumner Ordinance No. 2899, which mandates that grid-scale BESS facilities require a Conditional Use Permit (CUP) and are strictly prohibited within 1,000 feet of residential zones due to heightened fire hazards and environmental contamination risks. Furthermore, in alignment with SMC 18.04.1065 and City of Auburn Supplemental Development Standards (ACC 18.31.240), the PEIS must require standalone utility facilities to be restricted to industrial zones, provide secondary emergency vehicle access (EVA) routes, enforce strict noise decibel limits, and require fully funded 125% decommissioning bonds to protect municipalities from abandonment liability.
• Zoning Codes Must Be Strictly Construed: Siting models within the PEIS must respect established Washington judicial limits governing administrative authority. Administrative bodies and hearing examiners are prohibited from expanding or reinterpreting code categories beyond their plain terms (Zenner v. Dubuque County). Siting frameworks must be anchored to the rule that agencies may not "read into" an ordinance provisions that do not exist (Kilburn v. City of Bellevue), that zoning codes must be strictly construed (City of Seattle v. Crispin), and that administrative bodies cannot expand their authority beyond that granted by clear statutory law (Postema v. Pollution Control Hearings Board).
12. Local-Serving Use Restrictions and Compatibility Modeling
• Analysis Requested: The PEIS must explicitly evaluate whether a proposed facility serves a defined local community need or a purely regional industrial purpose. In alignment with Washington local subarea planning guidelines, the PEIS must mandate that facilities sited near rural commercial centers or residential areas demonstrate functional and visual compatibility with local rural character. Siting frameworks must reject the arbitrary rationale that grid connection automatically equates to "serving the local community." Siting models must mandate comprehensive, site-specific compatibility analyses supported by substantial record evidence—evaluating noise, visual buffers, and emergency staging parameters—rather than relying on generalized, boilerplate mitigation measures.
13. Critical Evaluation of Exploding Denominators, Baseline Biases, and 2026 Omissions
• The Denominator Distortion: Siting rules must reject industry-standard failure-rate graphs (such as the EPRI database charts) that divide reported failures by cumulative deployed Gigawatt-hours (GWh). When cumulative global deployment explodes exponentially, the failure rate per GWh mathematically plummets even if the actual number of individual facility fires rises or remains stubbornly persistent year after year. A global denominator creates an optical illusion of safety that fails to answer localized, site-specific community risks.
• The 33 Proprietary Incidents and OOBBBA PFE Supply Chain Crisis: Siting rules must not be built on data hidden from public examination. The state cannot declare that BESS transparency is improving while simultaneously asking the public to trust an analytical database containing 33 non-public incidents hidden from view. Siting rules must be evaluated against the profound regulatory and supply-chain realities introduced under the One Big Beautiful Bill Act (OBBBA) enacted on July 4, 2025. The OBBBA implemented highly complex, Foreign Entity of Concern (FEOC / PFE) rules, detailed in IRS Notice 2026-15, forcing developers seeking Section 48E commercial investment tax credits to calculate a strict Material Assistance Cost Ratio (MACR). Because foreign entities dominate the global processing of battery-grade lithium, graphite, and cobalt, standalone storage technology starting construction in 2026 must satisfy a minimum 55% non-PFE manufactured component cost threshold (escalating to 75% by 2030) or face total credit disallowance. Siting frameworks must evaluate how these extreme supply chain pressures and unresolved audit definitions create severe project volatility, delivery defaults, and data verification gaps across the state.
• The Chronological 2026 Failure Record: The distinction between incidents contained within an industry database and incidents occurring in the real world matters. Independent multilingual research utilizing local-language media, emergency response reports, and utility announcements reveals that industry-standard databases systematically omit a major ongoing pattern of verified stationary lithium BESS fires. To establish a legally defensible baseline under SEPA, the PEIS must evaluate and account for the following real-world 2026 BESS failure events:
• January 20, 2026 (Roodepoort, South South Africa): Fire involving a containerized lithium BESS integrated with solar.
• January 21, 2026 (San Marcos, CA): Fire in a containerized lithium BESS integrated at a commercial EV charging station.
• February 19, 2026 (Taebaek, South Korea): Frictional structural fire in a dedicated BESS battery room co-located with a solar array.
• March 16, 2026 (Valley Center, CA): Deflagration and fire in a grid-scale containerized lithium BESS.
• March 28, 2026 (Brekuso, Ghana): Complete failure and fire of a containerized lithium BESS paired with solar infrastructure.
• May 1, 2026 (Rainworth, UK): Thermal runaway event in a stacked NMC lithium battery energy storage facility.
• May 7, 2026 (Czajków, Poland): Structural containment fire in a containerized lithium BESS facility.
• May 14, 2026 (Nová Paka, Czech Republic): Siting failure resulting in a containerized lithium BESS thermal runaway fire.
• May 26, 2026 (Iririki Island, Vanuatu): Catastrophic lithium BESS fire in a dedicated utility building paired with solar arrays.
• June 12, 2026 (Shenzhen, China): Grid-scale containerized lithium BESS thermal runaway and failure.
• June 22, 2026 (Exeter, UK): Major failure resulting in a containerized lithium BESS fire.
• July 21, 2026 (Bautzen, Germany): Thermal runaway and structural containment failure of a containerized lithium BESS.
• August 4, 2026 (Douglas, Massachusetts): High-voltage containerized lithium battery energy storage system fire.
• August 26, 2026 (Buzau County, Romania): Containment breach and fire involving a containerized lithium BESS.
• September 7–21, 2026 (Summerside, Prince Edward Island, Canada): A massive, facility-wide thermal runaway event at the municipally owned Sunbank 20-MWh storage installation. The volatile chemical cells burned, smoldered, and flared uncontrollably for 14 straight days, physically resisting traditional water suppression. The incident forced localized shelter-in-place orders, a 500-meter voluntary evacuation perimeter, and localized emergency school closures due to toxic particulate plume exposure.
• September 18, 2026 (Moss Landing, CA): Re-ignition and fire at one of the world's largest lithium storage structures, where roughly 1,500 fully charged battery modules surviving a prior blaze spontaneously combusted during cleanup, prompting multi-agency evacuations, highway closures, and local shelter-in-place orders.
• September 22, 2026 (La Verne, CA): Severe BESS container explosion at a Southern California water treatment plant that blew the heavy steel doors entirely off the vault, creating an unstoppable thermal runaway cascade that completely breached and ignited a second adjacent BESS container overnight, resulting in multi-day regional hazardous material enforcement, a state of emergency declaration, the emergency closure of Grace Miller Elementary, and the evacuation of 500 nearby homes.
Because the industry's primary database excludes clearly identifiable stationary systems, the PEIS cannot treat it as an authoritative global count, and must assume real-world fire occurrence is underreported.
14. Material Sourcing, Transport Hazards, and Chemistry Alternatives
• The Myth of LFP Safety vs. Available Alternatives: Siting standards within the PEIS must reject the industry marketing narrative that Lithium Iron Phosphate (LFP) chemistry eliminates safety risks. Peer-reviewed adiabatic testing demonstrates that while LFP cathodes offer a threshold buffer over traditional NMC cells, LFP thermal runaway severity escalates aggressively with a high State of Charge (SOC), triggering massive, sustained heat generation rates up to 953.2°C/min. The PEIS must analyze alternative, inherently stable technologies—such as UL-listed sodium-ion batteries (e.g., Natron Energy architectures), zinc-based chemistries, iron-air systems, gravity batteries, or small-scale nuclear options—which physically cannot undergo thermal runaway.
• Corridor Transit Hazards: The PEIS must explicitly study and account for recent critical logistics failures across transit corridors, including the Interstate 90 battery transport fire in Issaquah, WA, the Interstate 15 lithium battery transport fire near Barstow, CA (which forced an absolute highway closure), and the Genius Star XI ocean transport failure offshore Alaska, where an industrial vessel carrying lithium-ion batteries suffered a massive hold fire that forced an extended offshore isolation zone to protect fisheries and local public health.
15. Hydrological Conduits, EFSEC Jurisdiction, and Macroeconomic Supply Shifting
• The Open-Excavation Fallout Pathway: Siting reviews must map and mandate analysis of specific contaminant pathways—such as thermal-runaway plume deposition and toxic firewater runoff dropping directly into open excavations, pits, or quarries that serve as direct vertical conduits straight to shallow groundwater tables within Category I Critical Aquifer Recharge Areas (CARAs). This must be cross-analyzed with post-incident research frameworks—such as the San Jose State University Moss Landing Marine Laboratories EMBER study—to evaluate how heavy metals (nickel, manganese, cobalt) released during a fire migrate via stormwater runoff into porewater, soils, and salmon-bearing aquatic ecosystems.
• Erosion of Local Authority via EFSEC and Loper Bright: The PEIS must address the profound institutional shift created by independent state authorities (such as EFSEC), deliberately designed to streamline state-selected energy projects by overriding local city codes, county comprehensive plans, and tribal treaty-reserved rights. This centralization has repeatedly disregarded vital local protections, mirroring the Yakama Nation's formal objections regarding the desecration of cultural landscapes in the Horse Heaven Hills project, and the sweeping opposition to the Goldeneye BESS project by the Sedro-Woolley City Council, Skagit County Commissioners, and the Upper Skagit Indian Tribe to protect the sensitive Hansen Creek salmon recovery watershed. Siting rules must be re-anchored to robust local determination, particularly given the U.S. Supreme Court's landmark ruling overturning Chevron deference in Loper Bright Enterprises v. Raimondo. Federal courts will no longer defer to broad, ambiguous administrative rules on environmental and climate policies; consequently, the state cannot shield developers under arbitrary public utility classifications, and must allow local jurisdictions to enforce strict home-rule protections to preserve the health, safety, and water security of Washington communities.
• The EV Supply-Overcapacity Dump and Consolidated AI Drivers: The PEIS must mandate a complete evaluation of the supply-side market distortion forcing the mass deployment of BESS projects across rural Washington. Siting trends demonstrate that this rapid expansion is not a response to local community utility demand, but rather a speculative capital redirection. Due to the termination of consumer residential EV credits under the OBBBA, global automakers and battery suppliers are experiencing catastrophic manufacturing overcapacity and multi-billion dollar program write-downs (such as Ford's $8.5 billion EV program rationalization and F-150 Lightning production freezes). Consequently, suppliers (such as LG Energy Solution) are aggressively redirecting excess EV-era battery manufacturing capacity into the stationary storage market to artificially maximize the utilization of existing factory lines. This manufacturing oversupply has triggered intense pricing compression, causing stationary pack prices to plummet 45% year-over-year (dropping imported Chinese systems to ~$95/kWh before tariffs). Private developers are weaponizing these cheap, imported overcapacity battery inventories, alongside the protected commercial tax equity of Section 48E, to build high-risk lithium installations en masse across Washington—principally to feed the unmitigated, skyrocketing infrastructure demands of corporate Artificial Intelligence (AI) data centers. Siting codes must explicitly require clear demonstration of direct local public demand to ensure Washington municipalities do not act as uncompensated hazard-containment zones for private data-center arbitrage at the expense of local public safety, critical habitat, and municipal groundwater—a threat exponentially amplified by massive utility consolidation, such as the proposed $67 billion NextEra Energy and Dominion merger, which is deliberately scaling a 130+ GW "large load pipeline" that treats local communities and sensitive ecosystems as mere sacrifice zones for centralized energy infrastructure.
The honest takeaway is not to "trust the graph." A global failure-rate line is not a fire protection plan, it is not proof of adequate setbacks, and it is not proof of local fire department readiness. Washington communities deserve rigorous, project-specific safety and environmental reviews before any facilities are approved.
Respectfully submitted,
Bonnie Helms↓
To the Clean Energy Coordination Team/Washington State Department of Ecology
Please accept these formal scoping comments regarding the development of the statewide BESS PE...↓IS siting rules and code frameworks must not rely on the flawed precedent of municipal DNS for nonproject actions. As documented in municipal SEPA reviews, nonproject zoning and code updates directly dictate the siting, scale, and long-term prevalence of volatile infrastructure across Washington. Characterizing these updates as nonproject actions to evade strict impact reviews creates profound analytical gaps that violate SEPA.
To ensure future project-level reviews across Washington are legally defensible and supported by substantial evidence, the Department of Ecology must utilize this PEIS to mandate a comprehensive SEPA review that explicitly rejects generalized industry claims and incorporates the following 15 core structural, technical, and data-reporting constraints:
1. Rejection of Presumed Future Regulatory Compliance
• Analysis Requested: The PEIS must reject any code frameworks that rely on the assumption that compliance with federal, state, and local regulations is "presumed" and that noncompliance can simply be managed by post-approval enforcement. Reliance on WAC 51-54A-1207 and NFPA 855 focuses strictly on isolated system design and immediate fire containment; it completely fails to evaluate the external environmental consequences of a facility-wide BESS failure, including toxic atmospheric migration, environmental deposition, and off-site human exposure. Presuming compliance with codes that do not evaluate these pathways does not substitute for actual environmental analysis.
2. Distinction Between Fire Behavior Containment and Acceptance of Impact
• Analysis Requested: The PEIS must recognize that mandatory large-scale fire testing (such as UL 9540A frameworks) evaluates whether a fire can be physically contained—not whether the environmental consequences of that fire are acceptable. The existing code framework permits systems to vent immense columns of hazardous gas, allows active fires to burn uncontrollably under "controlled burn" strategies, and manages thermal events through containment rather than prevention. Testing standards do not evaluate toxic gas generation, emission durations, or off-site transport and environmental deposition. Siting rules must address whether the external impacts of a managed burn are acceptable at the proposed location.
3. Inclusion of Failure-Related Emissions, Venting, and Plume Behavior
• Analysis Requested: Siting reviews must mandate site-specific atmospheric plume modeling and dispersion analysis. Siting checklists routinely omit emissions associated with BESS failure events, focusing exclusively on normal operations or construction dust. Because modern lithium-ion and Lithium Iron Phosphate (LFP) installations are structurally engineered to vent highly toxic gases under thermal runaway and failure conditions, the PEIS must mandate consequence modeling for the atmospheric transport and downwind fallout of these anticipated, catastrophic system behaviors to protect homes, schools, and transit corridors.
4. Prohibition of Post-Approval Hazard Mitigation Analysis (HMA) Deferral
• Analysis Requested: The PEIS must explicitly prohibit the "improper deferral" trap of approving project sites or municipal codes before critical safety reviews occur. Siting frameworks must require that the Hazard Mitigation Analysis (HMA) and site-specific Emergency Response Plans be completed, publicly disclosed, and formally evaluated prior to conditional land-use authorization. Allowing developers to complete core safety and risk evaluations post-approval forces decision-makers to conduct environmental reviews without knowing the actual system-specific risk profile, rendering the resulting safety determinations arbitrary and capricious.
5. Comprehensive Evaluation of Compound and Cascading Multi-Unit Failures
• Analysis Requested: Siting and risk reviews must model compound, real-world failure states rather than discrete, single failure modes. Documented battery storage failures demonstrate that modern incidents routinely involve cascading multi-unit propagation, violent chemical interactions between fire suppression systems and thermal runaway cells, and extended-duration events characterized by toxic off-gassing and sudden re-ignition weeks after initial containment.
6. Resolution of Ambiguity Between "Normal" and "Abnormal" States
• Analysis Requested: The PEIS must establish strict, non-ambiguous definitions for operational states. Relying on code frameworks that exempt standard operating or idle states from strict safety buffers creates severe vulnerabilities. Empirical data proves that catastrophic real-world battery failures frequently initiate during standard operating states, including idle and standby conditions, meaning failure pathways must be evaluated across all lifecycle states.
7. Evaluation of Passive Containment and Controlled Burn Consequences
• Analysis Requested: Siting codes must explicitly evaluate the environmental trade-offs of active versus passive fire management. Current code provisions do not mandate active fire suppression systems, allowing developers to deploy designs relying entirely on passive containment or controlled burns. The PEIS must model the severe environmental consequences of these design choices, specifically analyzing the extreme increase in fire durations and the immense cumulative volume of unmitigated toxic emissions released into the atmosphere during a prolonged passive burn.
8. Water and Groundwater Contamination Analysis Under Failure Conditions
• Analysis Requested: Siting rules must mandate self-contained, impervious secondary engineering containment basins and automated containment valves. Standard stormwater regulations are structurally incapable of handling the toxic byproducts of a battery disaster. When emergency responders apply millions of gallons of water to cool a burning installation, the resulting runoff carries heavy metals and corrosive hydrofluoric acid. Siting reviews must evaluate the volume and chemical composition of this contaminated runoff, its transport through local soils, and its long-term impact on critical groundwater tables and salmon-bearing aquatic ecosystems.
9. Internal Consistency and Regional Burden in Emergency Response Analysis
• Analysis Requested: Siting frameworks must eliminate the internal inconsistency of claiming a BESS project will not generate a demand for special emergency services while simultaneously acknowledging that BESS failures must be treated as complex, multi-agency hazardous materials incidents. The PEIS must model the real-world operational strains of a BESS failure, documenting how a single localized fire requires specialized regional Hazmat capabilities, specialized PPE, and the prolonged on-site deployment of local fire district resources to monitor for sudden re-ignition.
10. Meaningful Pre-Approval Evaluation of Critical Areas
• Analysis Requested: Siting maps must actively restrict utility-scale battery installations from being placed within sensitive environmental features. Deferring to future project-level compliance does not fulfill SEPA's mandate to protect critical areas. The PEIS must evaluate whether broad siting ordinances adequately shield Critical Aquifer Recharge Areas (CARAs), geologically hazardous zones, wetlands, and sensitive wildlife habitats from toxic fallout before any project boundaries are established.
11. Siting Boundaries, Judicial Limits, and More Protective Alternatives
• The Sumner/Auburn Precedents: Siting rules must formally adopt more protective regulatory choices, recognizing that the severe environmental impacts of battery infrastructure are entirely dependent on the stringency of the adopted framework. The PEIS must look to existing Washington municipal precedents, specifically City of Sumner Ordinance No. 2899, which mandates that grid-scale BESS facilities require a Conditional Use Permit (CUP) and are strictly prohibited within 1,000 feet of residential zones due to heightened fire hazards and environmental contamination risks. Furthermore, in alignment with SMC 18.04.1065 and City of Auburn Supplemental Development Standards (ACC 18.31.240), the PEIS must require standalone utility facilities to be restricted to industrial zones, provide secondary emergency vehicle access (EVA) routes, enforce strict noise decibel limits, and require fully funded 125% decommissioning bonds to protect municipalities from abandonment liability.
• Zoning Codes Must Be Strictly Construed: Siting models within the PEIS must respect established Washington judicial limits governing administrative authority. Administrative bodies and hearing examiners are prohibited from expanding or reinterpreting code categories beyond their plain terms (Zenner v. Dubuque County). Siting frameworks must be anchored to the rule that agencies may not "read into" an ordinance provisions that do not exist (Kilburn v. City of Bellevue), that zoning codes must be strictly construed (City of Seattle v. Crispin), and that administrative bodies cannot expand their authority beyond that granted by clear statutory law (Postema v. Pollution Control Hearings Board).
12. Local-Serving Use Restrictions and Compatibility Modeling
• Analysis Requested: The PEIS must explicitly evaluate whether a proposed facility serves a defined local community need or a purely regional industrial purpose. In alignment with Washington local subarea planning guidelines, the PEIS must mandate that facilities sited near rural commercial centers or residential areas demonstrate functional and visual compatibility with local rural character. Siting frameworks must reject the arbitrary rationale that grid connection automatically equates to "serving the local community." Siting models must mandate comprehensive, site-specific compatibility analyses supported by substantial record evidence—evaluating noise, visual buffers, and emergency staging parameters—rather than relying on generalized, boilerplate mitigation measures.
13. Critical Evaluation of Exploding Denominators, Baseline Biases, and 2026 Omissions
• The Denominator Distortion: Siting rules must reject industry-standard failure-rate graphs (such as the EPRI database charts) that divide reported failures by cumulative deployed Gigawatt-hours (GWh). When cumulative global deployment explodes exponentially, the failure rate per GWh mathematically plummets even if the actual number of individual facility fires rises or remains stubbornly persistent year after year. A global denominator creates an optical illusion of safety that fails to answer localized, site-specific community risks.
• The 33 Proprietary Incidents and OOBBBA PFE Supply Chain Crisis: Siting rules must not be built on data hidden from public examination. The state cannot declare that BESS transparency is improving while simultaneously asking the public to trust an analytical database containing 33 non-public incidents hidden from view. Siting rules must be evaluated against the profound regulatory and supply-chain realities introduced under the One Big Beautiful Bill Act (OBBBA) enacted on July 4, 2025. The OBBBA implemented highly complex, Foreign Entity of Concern (FEOC / PFE) rules, detailed in IRS Notice 2026-15, forcing developers seeking Section 48E commercial investment tax credits to calculate a strict Material Assistance Cost Ratio (MACR). Because foreign entities dominate the global processing of battery-grade lithium, graphite, and cobalt, standalone storage technology starting construction in 2026 must satisfy a minimum 55% non-PFE manufactured component cost threshold (escalating to 75% by 2030) or face total credit disallowance. Siting frameworks must evaluate how these extreme supply chain pressures and unresolved audit definitions create severe project volatility, delivery defaults, and data verification gaps across the state.
• The Chronological 2026 Failure Record: The distinction between incidents contained within an industry database and incidents occurring in the real world matters. Independent multilingual research utilizing local-language media, emergency response reports, and utility announcements reveals that industry-standard databases systematically omit a major ongoing pattern of verified stationary lithium BESS fires. To establish a legally defensible baseline under SEPA, the PEIS must evaluate and account for the following real-world 2026 BESS failure events:
• January 20, 2026 (Roodepoort, South South Africa): Fire involving a containerized lithium BESS integrated with solar.
• January 21, 2026 (San Marcos, CA): Fire in a containerized lithium BESS integrated at a commercial EV charging station.
• February 19, 2026 (Taebaek, South Korea): Frictional structural fire in a dedicated BESS battery room co-located with a solar array.
• March 16, 2026 (Valley Center, CA): Deflagration and fire in a grid-scale containerized lithium BESS.
• March 28, 2026 (Brekuso, Ghana): Complete failure and fire of a containerized lithium BESS paired with solar infrastructure.
• May 1, 2026 (Rainworth, UK): Thermal runaway event in a stacked NMC lithium battery energy storage facility.
• May 7, 2026 (Czajków, Poland): Structural containment fire in a containerized lithium BESS facility.
• May 14, 2026 (Nová Paka, Czech Republic): Siting failure resulting in a containerized lithium BESS thermal runaway fire.
• May 26, 2026 (Iririki Island, Vanuatu): Catastrophic lithium BESS fire in a dedicated utility building paired with solar arrays.
• June 12, 2026 (Shenzhen, China): Grid-scale containerized lithium BESS thermal runaway and failure.
• June 22, 2026 (Exeter, UK): Major failure resulting in a containerized lithium BESS fire.
• July 21, 2026 (Bautzen, Germany): Thermal runaway and structural containment failure of a containerized lithium BESS.
• August 4, 2026 (Douglas, Massachusetts): High-voltage containerized lithium battery energy storage system fire.
• August 26, 2026 (Buzau County, Romania): Containment breach and fire involving a containerized lithium BESS.
• September 7–21, 2026 (Summerside, Prince Edward Island, Canada): A massive, facility-wide thermal runaway event at the municipally owned Sunbank 20-MWh storage installation. The volatile chemical cells burned, smoldered, and flared uncontrollably for 14 straight days, physically resisting traditional water suppression. The incident forced localized shelter-in-place orders, a 500-meter voluntary evacuation perimeter, and localized emergency school closures due to toxic particulate plume exposure.
• September 18, 2026 (Moss Landing, CA): Re-ignition and fire at one of the world's largest lithium storage structures, where roughly 1,500 fully charged battery modules surviving a prior blaze spontaneously combusted during cleanup, prompting multi-agency evacuations, highway closures, and local shelter-in-place orders.
• September 22, 2026 (La Verne, CA): Severe BESS container explosion at a Southern California water treatment plant that blew the heavy steel doors entirely off the vault, creating an unstoppable thermal runaway cascade that completely breached and ignited a second adjacent BESS container overnight, resulting in multi-day regional hazardous material enforcement, a state of emergency declaration, the emergency closure of Grace Miller Elementary, and the evacuation of 500 nearby homes.
Because the industry's primary database excludes clearly identifiable stationary systems, the PEIS cannot treat it as an authoritative global count, and must assume real-world fire occurrence is underreported.
14. Material Sourcing, Transport Hazards, and Chemistry Alternatives
• The Myth of LFP Safety vs. Available Alternatives: Siting standards within the PEIS must reject the industry marketing narrative that Lithium Iron Phosphate (LFP) chemistry eliminates safety risks. Peer-reviewed adiabatic testing demonstrates that while LFP cathodes offer a threshold buffer over traditional NMC cells, LFP thermal runaway severity escalates aggressively with a high State of Charge (SOC), triggering massive, sustained heat generation rates up to 953.2°C/min. The PEIS must analyze alternative, inherently stable technologies—such as UL-listed sodium-ion batteries (e.g., Natron Energy architectures), zinc-based chemistries, iron-air systems, gravity batteries, or small-scale nuclear options—which physically cannot undergo thermal runaway.
• Corridor Transit Hazards: The PEIS must explicitly study and account for recent critical logistics failures across transit corridors, including the Interstate 90 battery transport fire in Issaquah, WA, the Interstate 15 lithium battery transport fire near Barstow, CA (which forced an absolute highway closure), and the Genius Star XI ocean transport failure offshore Alaska, where an industrial vessel carrying lithium-ion batteries suffered a massive hold fire that forced an extended offshore isolation zone to protect fisheries and local public health.
15. Hydrological Conduits, EFSEC Jurisdiction, and Macroeconomic Supply Shifting
• The Open-Excavation Fallout Pathway: Siting reviews must map and mandate analysis of specific contaminant pathways—such as thermal-runaway plume deposition and toxic firewater runoff dropping directly into open excavations, pits, or quarries that serve as direct vertical conduits straight to shallow groundwater tables within Category I Critical Aquifer Recharge Areas (CARAs). This must be cross-analyzed with post-incident research frameworks—such as the San Jose State University Moss Landing Marine Laboratories EMBER study—to evaluate how heavy metals (nickel, manganese, cobalt) released during a fire migrate via stormwater runoff into porewater, soils, and salmon-bearing aquatic ecosystems.
• Erosion of Local Authority via EFSEC and Loper Bright: The PEIS must address the profound institutional shift created by independent state authorities (such as EFSEC), deliberately designed to streamline state-selected energy projects by overriding local city codes, county comprehensive plans, and tribal treaty-reserved rights. This centralization has repeatedly disregarded vital local protections, mirroring the Yakama Nation's formal objections regarding the desecration of cultural landscapes in the Horse Heaven Hills project, and the sweeping opposition to the Goldeneye BESS project by the Sedro-Woolley City Council, Skagit County Commissioners, and the Upper Skagit Indian Tribe to protect the sensitive Hansen Creek salmon recovery watershed. Siting rules must be re-anchored to robust local determination, particularly given the U.S. Supreme Court's landmark ruling overturning Chevron deference in Loper Bright Enterprises v. Raimondo. Federal courts will no longer defer to broad, ambiguous administrative rules on environmental and climate policies; consequently, the state cannot shield developers under arbitrary public utility classifications, and must allow local jurisdictions to enforce strict home-rule protections to preserve the health, safety, and water security of Washington communities.
• The EV Supply-Overcapacity Dump and Consolidated AI Drivers: The PEIS must mandate a complete evaluation of the supply-side market distortion forcing the mass deployment of BESS projects across rural Washington. Siting trends demonstrate that this rapid expansion is not a response to local community utility demand, but rather a speculative capital redirection. Due to the termination of consumer residential EV credits under the OBBBA, global automakers and battery suppliers are experiencing catastrophic manufacturing overcapacity and multi-billion dollar program write-downs (such as Ford's $8.5 billion EV program rationalization and F-150 Lightning production freezes). Consequently, suppliers (such as LG Energy Solution) are aggressively redirecting excess EV-era battery manufacturing capacity into the stationary storage market to artificially maximize the utilization of existing factory lines. This manufacturing oversupply has triggered intense pricing compression, causing stationary pack prices to plummet 45% year-over-year (dropping imported Chinese systems to ~$95/kWh before tariffs). Private developers are weaponizing these cheap, imported overcapacity battery inventories, alongside the protected commercial tax equity of Section 48E, to build high-risk lithium installations en masse across Washington—principally to feed the unmitigated, skyrocketing infrastructure demands of corporate Artificial Intelligence (AI) data centers. Siting codes must explicitly require clear demonstration of direct local public demand to ensure Washington municipalities do not act as uncompensated hazard-containment zones for private data-center arbitrage at the expense of local public safety, critical habitat, and municipal groundwater—a threat exponentially amplified by massive utility consolidation, such as the proposed $67 billion NextEra Energy and Dominion merger, which is deliberately scaling a 130+ GW "large load pipeline" that treats local communities and sensitive ecosystems as mere sacrifice zones for centralized energy infrastructure.
The honest takeaway is not to "trust the graph." A global failure-rate line is not a fire protection plan, it is not proof of adequate setbacks, and it is not proof of local fire department readiness. Washington communities deserve rigorous, project-specific safety and environmental reviews before any facilities are approved.
Respectfully submitted,
Bonnie Helms↓
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To the Department of Ecology, Clean Energy Coordination:
My name is Marla Person and I live at 7828 Douglas Ave, SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-...↓ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. The study should look at what a multi-day battery fire demands from local fire, hazmat, hospital, and evacuation capacity, since Ecology could not say whether the burden on small rural fire districts can be fixed.
We have just begun to see the effects of lithium battery fire events, Warwick New York, Moss Landing California, 2021, 2022, 2025 and September 18, 2026. There was even a fire at a small accessory BESS In Laverne California September 22, 2026. A tiny, newer facility with the latest technology batteries exploded and caught fire. That facility was new, having just been commissioned early in summer 2026, was only 1 MW and evacuated over 500 residents. Here Jupiter/Black Rock and EFSEC are considering allowing a 130 megawatt facility, over 33 football fields of batteries where we have over 2000 children, babies and students using facilities within a few hundred feet to one half mile of the proposed Cascadia Site. You need to be absolutely sure that you are doing the right thing by placing this adjacent next to so many residential homes and children. One in three residents in our neighborhood is a child..... Any event large even or small will incite a huge lawsuit after the fight the community presented. With well-documented issues brought up including: evacuation planning shortfalls, lack of egress, failing bridges and large amounts critical areas including our watershed that supplies drinking water for thousands of king county residents. Fallout or issues here will also taint and hinder any future infrastructure buildout as far as BESS facilities in our state, forever.
I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Cascades Ridge project. My children attend school near a proposed stand-alone BESS site, at Cascade. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Marla Person
7828 Douglas Ave, SE↓
My name is Marla Person and I live at 7828 Douglas Ave, SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-...↓ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. The study should look at what a multi-day battery fire demands from local fire, hazmat, hospital, and evacuation capacity, since Ecology could not say whether the burden on small rural fire districts can be fixed.
We have just begun to see the effects of lithium battery fire events, Warwick New York, Moss Landing California, 2021, 2022, 2025 and September 18, 2026. There was even a fire at a small accessory BESS In Laverne California September 22, 2026. A tiny, newer facility with the latest technology batteries exploded and caught fire. That facility was new, having just been commissioned early in summer 2026, was only 1 MW and evacuated over 500 residents. Here Jupiter/Black Rock and EFSEC are considering allowing a 130 megawatt facility, over 33 football fields of batteries where we have over 2000 children, babies and students using facilities within a few hundred feet to one half mile of the proposed Cascadia Site. You need to be absolutely sure that you are doing the right thing by placing this adjacent next to so many residential homes and children. One in three residents in our neighborhood is a child..... Any event large even or small will incite a huge lawsuit after the fight the community presented. With well-documented issues brought up including: evacuation planning shortfalls, lack of egress, failing bridges and large amounts critical areas including our watershed that supplies drinking water for thousands of king county residents. Fallout or issues here will also taint and hinder any future infrastructure buildout as far as BESS facilities in our state, forever.
I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Cascades Ridge project. My children attend school near a proposed stand-alone BESS site, at Cascade. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Marla Person
7828 Douglas Ave, SE↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Kurt Schreiber and I live at 34214 SE Carmichael Street. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, ...↓lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I would like the study to name specific, measurable protections a permit can require. Protections described "at a high level" give my county nothing to write into a permit. The study should be specific enough to give local reviewers something to hold a developer to, because my county will lean on it when it reviews a real project. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My children attend school near a proposed stand-alone BESS site, at Cascade View. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Kurt Schreiber
34214 SE Carmichael Street↓
My name is Kurt Schreiber and I live at 34214 SE Carmichael Street. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, ...↓lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I would like the study to name specific, measurable protections a permit can require. Protections described "at a high level" give my county nothing to write into a permit. The study should be specific enough to give local reviewers something to hold a developer to, because my county will lean on it when it reviews a real project. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My children attend school near a proposed stand-alone BESS site, at Cascade View. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Kurt Schreiber
34214 SE Carmichael Street↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Jon Schrader. I live at 7722 Greenridge Ct. SE in Snoqualmie Ridge. This is my scoping comment on the Programmatic EIS for stand-alone, utility-scale lithium-ion battery energy stor...↓age systems (Publication 26-06-017).
Jupiter Power has proposed a stand-alone BESS facility, the Cascadia Ridge project, near my neighborhood. My kids go to Snoqualmie Elementary, near the proposed site. My family depends on Snoqualmie Parkway, which is also the emergency route for everyone who lives along it. Ecology has said project-level reviews will tier to this PEIS, so this study will set the baseline for how a project like Cascadia Ridge gets evaluated.
The PEIS should start from four realities.
Fires will happen. Failure rates per installed unit have improved, but across a growing fleet and a 20-plus-year operating life, a thermal runaway event is a statistically probable outcome, not a remote one. The PEIS should plan for the fire, not just for the odds of preventing it.
The impacts don't stay inside the fence. Toxic gases including hydrogen fluoride, smoke, contaminated runoff, and explosion risk all travel. With homes within 500 feet of the proposed site, the risk is at the community's doorstep, and nothing enforceable currently protects the people living there. These events are dangerous even to trained, equipped responders. Firefighters were seriously injured in the 2019 McMicken explosion in Arizona, and two firefighters were killed in a 2021 battery storage explosion in Beijing. There are documented cases of first responders battling long term health issues due to proximity to Lithium Ion Battery Fires. Residents should not be expected to have personal protective gear in their homes (for themselves AND guests) and may have no way out. Shelter in place is the expectation for residents within specific proximity.
The aftermath lasts years. Moss Landing burned in January 2025. More than a year and a half later the damaged batteries are still being removed, and the EPA doesn't expect cleanup to finish until mid-2027. That happened in a town of fewer than 1,000 people. The PEIS needs to account for what the same event means inside a community with 10's of thousands of residents, with schools, a hospital, and other vulnerable residents nearby.
The risk is being shifted onto residents. King County's BESS ordinance caps developer liability at $1 million. That is a small fraction of what a Moss Landing-scale response and cleanup costs. If the developer won't be fully accountable for the consequences of a failure, the community can't be asked to accept the risk. The PEIS should treat full financial accountability as a precondition, not an afterthought.
Q1 · Facility types
Ecology's earlier studies looked at remote sites. Stand-alone BESS is different. Ecology itself says these facilities "could be sited in a variety of locations," and in practice that means rows of shipping-container-sized battery units next to homes and schools. The PEIS should study that scenario, including the largest container installations being proposed today, not just small substation batteries.
The analysis should assume facilities are built to the code Washington has actually adopted, not the newest standards, since Ecology acknowledges the state's fire code lags behind. Then it should spell out what the current edition of NFPA 855 and UL 9540A large-scale fire testing would change. Safety conclusions should rest on independent incident data, not developer assurances.
Q2 · Geographic scope
"Suitable" should mean safe for the people who live there, not just buildable. Proximity to a substation or transmission line is a grid convenience, not a safety finding, and it shouldn't be treated as one.
Because site details get pushed to later reviews, this is the one chance to shape the study area. The PEIS map should say where facilities should not go, not only where they could. At minimum it should screen for:
• proximity to homes, schools, and hospitals
• wildland-urban interface and wildfire-prone areas, along with local fire-district capacity (Ecology's earlier studies already flagged "new ignition sources in remote locations with limited response capabilities")
• mapped seismic hazard zones and floodplains
• areas that rely on private wells
• communities with limited evacuation routes
The Snoqualmie Valley has most of these conditions at once. It's a good test case for whether the screening works.
Q3 · Impacts to analyze
The scoping document says Ecology "will evaluate" responder training, hard-to-extinguish fires, toxic emissions, water and fish impacts, and cleanup. Each of those needs a full analysis, not a sentence. Specifically:
• Toxic gas exposure for neighbors, not just firefighters. The scoping document notes that gases from damaged batteries can harm firefighters' skin and lungs. It says nothing about residents, who have no protective gear and may not be able to leave. The PEIS should run dispersion modeling for hydrogen fluoride and other thermal-runaway gases under valley inversion conditions, which trap air at ground level.
• Evacuation and displacement as impacts in their own right. Moss Landing, Ecology's own example, forced roughly 1,200 people from their homes.
• Firefighting water. Contaminated suppression runoff and its path to groundwater, private wells, and fish-bearing streams.
• Multi-day incident demand. What an extended BESS fire requires from local fire, HazMat, hospital, and evacuation resources. Ecology could not previously say whether the burden on small fire districts can be mitigated, and our own district, Eastside Fire & Rescue, has publicly said it isn't prepared for a BESS incident.
• Explosion risk. Deflagration from off-gassing, as in the 2019 McMicken incident in Arizona, where firefighters were injured.
• Nighttime noise measured at the nearest home, not the fence line. Ecology's earlier studies found facility noise carrying 1,000 feet in quiet rural areas; the analysis should go beyond that distance.
• Seismic performance of container installations in mapped fault zones.
Q4 · Mitigation
Mitigation described "at a high level" gives King County nothing to put in a permit. The county will lean on this PEIS when it reviews a real project, so the measures need to be specific and enforceable:
• minimum setbacks from homes, schools, hospitals, and drinking-water wells, backed by evidence that the distance is actually protective
• UL 9540A large-scale fire testing and compliance with the current edition of NFPA 855 for every facility, regardless of what the state has adopted, since Ecology credits large-scale testing with reducing risk
• funded emergency response plans, training, and equipment for local fire districts in place before a facility operates
• containment and disposal plans for fire-suppression water
• enforceable nighttime noise limits at the nearest residence
• decommissioning plans and financial assurance sized to a worst-case incident and cleanup. King County's current $1 million liability cap doesn't come close to that.
Where a harm can't be reduced below significance, such as a fire a small district can't contain, the PEIS should say so plainly and call it unavoidable. Lead agencies and the public shouldn't have to guess.
Q5 · Lithium-ion chemistry and alternatives
This PEIS is scoped to lithium-ion, but SEPA requires a look at reasonable alternatives. Many of lithium-ion's problems come from the chemistry itself, not just from where a facility is sited. Better setbacks don't fix them. The PEIS should evaluate these problems directly and compare lithium-ion against non-lithium storage such as sodium-ion, iron-air, and flow batteries.
• Toxicity. Burning or venting lithium-ion cells release hydrogen fluoride, carbon monoxide, and other toxic gases. The electrolyte can generate HF even without open flame once a cell vents. Nickel-manganese-cobalt (NMC) cells also contain heavy metals, and after Moss Landing, researchers found elevated nickel, manganese, and cobalt in nearby marsh soils. Many cells also use fluorinated binders from the PFAS family. The PEIS should analyze what settles out after an incident on soil, gardens, school fields, and surface water, not just what is in the air during the event.
• Instability. Thermal runaway is self-sustaining. A failing cell produces its own heat and flammable gas, spreads to its neighbors, and cannot be reliably extinguished, only cooled or allowed to burn out. Damaged cells keep stranded energy and can reignite days or months later. Moss Landing flared up again a month after the main fire, and responders there still cite reignition risk during cleanup. Lithium iron phosphate (LFP) is more stable than NMC, but it still vents flammable gas that can explode inside an enclosed container. The PEIS should compare runaway behavior by chemistry and should not treat a switch to LFP as solving the problem.
• Cooling, HVAC, and noise. Lithium-ion has to be held in a narrow temperature band. That means chillers, fans, and inverters running 24 hours a day, year-round, including the low-frequency hum that carries at night and through walls. A cooling failure is itself a runaway trigger, refrigerants add a greenhouse-gas leak risk, and the cooling load cuts the facility's net efficiency. The PEIS should quantify cooling-system noise, including low-frequency and tonal components (dBC, not just dBA). It should also identify refrigerant types and leak rates, and analyze what happens when cooling or site power fails.
• Supply chain ethics. Much of the world's cobalt comes from the Democratic Republic of Congo, including artisanal mines with documented child labor. Lithium brine extraction in South America draws down water in arid regions that Indigenous communities depend on. Graphite and cell processing are concentrated in China, with forced-labor concerns serious enough that federal import law now targets parts of that chain. Washington shouldn't approve "clean" energy whose harms are simply exported. The PEIS should include a lifecycle analysis of the chemistries it covers, and it should require project applicants to disclose cell chemistry, manufacturer, and material sourcing.
I ask that the PEIS evaluate non-lithium storage chemistries as reasonable alternatives. It should compare chemistries on fire behavior, toxic emissions, cooling demand, and noise. It should also require project-level disclosure of chemistry and supply chain, so lead agencies know what is actually being built.
Closing
Bottom line: Ecology's own framing says these facilities can go almost anywhere, including next to neighborhoods. The PEIS should treat proximity to residents as a defining condition of the analysis, not an edge case. It should also take a hard look at whether lithium-ion is the right chemistry to put there at all.
Please include this comment in the scoping record. Our community is following this closely and will be commenting on the Draft PEIS.
Jon Schrader 7722 Greenridge Ct. SE Snoqualmie, WA↓
My name is Jon Schrader. I live at 7722 Greenridge Ct. SE in Snoqualmie Ridge. This is my scoping comment on the Programmatic EIS for stand-alone, utility-scale lithium-ion battery energy stor...↓age systems (Publication 26-06-017).
Jupiter Power has proposed a stand-alone BESS facility, the Cascadia Ridge project, near my neighborhood. My kids go to Snoqualmie Elementary, near the proposed site. My family depends on Snoqualmie Parkway, which is also the emergency route for everyone who lives along it. Ecology has said project-level reviews will tier to this PEIS, so this study will set the baseline for how a project like Cascadia Ridge gets evaluated.
The PEIS should start from four realities.
Fires will happen. Failure rates per installed unit have improved, but across a growing fleet and a 20-plus-year operating life, a thermal runaway event is a statistically probable outcome, not a remote one. The PEIS should plan for the fire, not just for the odds of preventing it.
The impacts don't stay inside the fence. Toxic gases including hydrogen fluoride, smoke, contaminated runoff, and explosion risk all travel. With homes within 500 feet of the proposed site, the risk is at the community's doorstep, and nothing enforceable currently protects the people living there. These events are dangerous even to trained, equipped responders. Firefighters were seriously injured in the 2019 McMicken explosion in Arizona, and two firefighters were killed in a 2021 battery storage explosion in Beijing. There are documented cases of first responders battling long term health issues due to proximity to Lithium Ion Battery Fires. Residents should not be expected to have personal protective gear in their homes (for themselves AND guests) and may have no way out. Shelter in place is the expectation for residents within specific proximity.
The aftermath lasts years. Moss Landing burned in January 2025. More than a year and a half later the damaged batteries are still being removed, and the EPA doesn't expect cleanup to finish until mid-2027. That happened in a town of fewer than 1,000 people. The PEIS needs to account for what the same event means inside a community with 10's of thousands of residents, with schools, a hospital, and other vulnerable residents nearby.
The risk is being shifted onto residents. King County's BESS ordinance caps developer liability at $1 million. That is a small fraction of what a Moss Landing-scale response and cleanup costs. If the developer won't be fully accountable for the consequences of a failure, the community can't be asked to accept the risk. The PEIS should treat full financial accountability as a precondition, not an afterthought.
Q1 · Facility types
Ecology's earlier studies looked at remote sites. Stand-alone BESS is different. Ecology itself says these facilities "could be sited in a variety of locations," and in practice that means rows of shipping-container-sized battery units next to homes and schools. The PEIS should study that scenario, including the largest container installations being proposed today, not just small substation batteries.
The analysis should assume facilities are built to the code Washington has actually adopted, not the newest standards, since Ecology acknowledges the state's fire code lags behind. Then it should spell out what the current edition of NFPA 855 and UL 9540A large-scale fire testing would change. Safety conclusions should rest on independent incident data, not developer assurances.
Q2 · Geographic scope
"Suitable" should mean safe for the people who live there, not just buildable. Proximity to a substation or transmission line is a grid convenience, not a safety finding, and it shouldn't be treated as one.
Because site details get pushed to later reviews, this is the one chance to shape the study area. The PEIS map should say where facilities should not go, not only where they could. At minimum it should screen for:
• proximity to homes, schools, and hospitals
• wildland-urban interface and wildfire-prone areas, along with local fire-district capacity (Ecology's earlier studies already flagged "new ignition sources in remote locations with limited response capabilities")
• mapped seismic hazard zones and floodplains
• areas that rely on private wells
• communities with limited evacuation routes
The Snoqualmie Valley has most of these conditions at once. It's a good test case for whether the screening works.
Q3 · Impacts to analyze
The scoping document says Ecology "will evaluate" responder training, hard-to-extinguish fires, toxic emissions, water and fish impacts, and cleanup. Each of those needs a full analysis, not a sentence. Specifically:
• Toxic gas exposure for neighbors, not just firefighters. The scoping document notes that gases from damaged batteries can harm firefighters' skin and lungs. It says nothing about residents, who have no protective gear and may not be able to leave. The PEIS should run dispersion modeling for hydrogen fluoride and other thermal-runaway gases under valley inversion conditions, which trap air at ground level.
• Evacuation and displacement as impacts in their own right. Moss Landing, Ecology's own example, forced roughly 1,200 people from their homes.
• Firefighting water. Contaminated suppression runoff and its path to groundwater, private wells, and fish-bearing streams.
• Multi-day incident demand. What an extended BESS fire requires from local fire, HazMat, hospital, and evacuation resources. Ecology could not previously say whether the burden on small fire districts can be mitigated, and our own district, Eastside Fire & Rescue, has publicly said it isn't prepared for a BESS incident.
• Explosion risk. Deflagration from off-gassing, as in the 2019 McMicken incident in Arizona, where firefighters were injured.
• Nighttime noise measured at the nearest home, not the fence line. Ecology's earlier studies found facility noise carrying 1,000 feet in quiet rural areas; the analysis should go beyond that distance.
• Seismic performance of container installations in mapped fault zones.
Q4 · Mitigation
Mitigation described "at a high level" gives King County nothing to put in a permit. The county will lean on this PEIS when it reviews a real project, so the measures need to be specific and enforceable:
• minimum setbacks from homes, schools, hospitals, and drinking-water wells, backed by evidence that the distance is actually protective
• UL 9540A large-scale fire testing and compliance with the current edition of NFPA 855 for every facility, regardless of what the state has adopted, since Ecology credits large-scale testing with reducing risk
• funded emergency response plans, training, and equipment for local fire districts in place before a facility operates
• containment and disposal plans for fire-suppression water
• enforceable nighttime noise limits at the nearest residence
• decommissioning plans and financial assurance sized to a worst-case incident and cleanup. King County's current $1 million liability cap doesn't come close to that.
Where a harm can't be reduced below significance, such as a fire a small district can't contain, the PEIS should say so plainly and call it unavoidable. Lead agencies and the public shouldn't have to guess.
Q5 · Lithium-ion chemistry and alternatives
This PEIS is scoped to lithium-ion, but SEPA requires a look at reasonable alternatives. Many of lithium-ion's problems come from the chemistry itself, not just from where a facility is sited. Better setbacks don't fix them. The PEIS should evaluate these problems directly and compare lithium-ion against non-lithium storage such as sodium-ion, iron-air, and flow batteries.
• Toxicity. Burning or venting lithium-ion cells release hydrogen fluoride, carbon monoxide, and other toxic gases. The electrolyte can generate HF even without open flame once a cell vents. Nickel-manganese-cobalt (NMC) cells also contain heavy metals, and after Moss Landing, researchers found elevated nickel, manganese, and cobalt in nearby marsh soils. Many cells also use fluorinated binders from the PFAS family. The PEIS should analyze what settles out after an incident on soil, gardens, school fields, and surface water, not just what is in the air during the event.
• Instability. Thermal runaway is self-sustaining. A failing cell produces its own heat and flammable gas, spreads to its neighbors, and cannot be reliably extinguished, only cooled or allowed to burn out. Damaged cells keep stranded energy and can reignite days or months later. Moss Landing flared up again a month after the main fire, and responders there still cite reignition risk during cleanup. Lithium iron phosphate (LFP) is more stable than NMC, but it still vents flammable gas that can explode inside an enclosed container. The PEIS should compare runaway behavior by chemistry and should not treat a switch to LFP as solving the problem.
• Cooling, HVAC, and noise. Lithium-ion has to be held in a narrow temperature band. That means chillers, fans, and inverters running 24 hours a day, year-round, including the low-frequency hum that carries at night and through walls. A cooling failure is itself a runaway trigger, refrigerants add a greenhouse-gas leak risk, and the cooling load cuts the facility's net efficiency. The PEIS should quantify cooling-system noise, including low-frequency and tonal components (dBC, not just dBA). It should also identify refrigerant types and leak rates, and analyze what happens when cooling or site power fails.
• Supply chain ethics. Much of the world's cobalt comes from the Democratic Republic of Congo, including artisanal mines with documented child labor. Lithium brine extraction in South America draws down water in arid regions that Indigenous communities depend on. Graphite and cell processing are concentrated in China, with forced-labor concerns serious enough that federal import law now targets parts of that chain. Washington shouldn't approve "clean" energy whose harms are simply exported. The PEIS should include a lifecycle analysis of the chemistries it covers, and it should require project applicants to disclose cell chemistry, manufacturer, and material sourcing.
I ask that the PEIS evaluate non-lithium storage chemistries as reasonable alternatives. It should compare chemistries on fire behavior, toxic emissions, cooling demand, and noise. It should also require project-level disclosure of chemistry and supply chain, so lead agencies know what is actually being built.
Closing
Bottom line: Ecology's own framing says these facilities can go almost anywhere, including next to neighborhoods. The PEIS should treat proximity to residents as a defining condition of the analysis, not an edge case. It should also take a hard look at whether lithium-ion is the right chemistry to put there at all.
Please include this comment in the scoping record. Our community is following this closely and will be commenting on the Draft PEIS.
Jon Schrader 7722 Greenridge Ct. SE Snoqualmie, WA↓
No attachments
BESS present safety, sound, odor, emissions, visual, environmental, and end-of-service life decommissioning concerns.
BESS occasionally erupt into fire spontaneously when a thermal runaway event occurs. As of April 2023, the fire incident rate at l...↓arge-scale BESS facilities was 2.9%. The average age of BESS that caught fire was 18 months. Sources "Energy Storage Policy Database," Pacific Northwest National Laboratory, referenced by the University of Michigan, Ford School of Public Policy "Battery Energy Storage System Deployment: Local and State Policy Considerations" June 2024 white paper. In contrast, the estimated restaurant fire incident rate is .7%.
BESS fires are difficult to extinguish, may re-erupt after initial extinguishment, and may burn for multiple days before being finally brought under control.
Controlling BESS fires requires specialized training. Battery fires release toxic gases, but the primary risk of local environmental contamination is the use of water in fire suppression. Water binds to chemicals released during a BESS fire, which may contaminate groundwater, stormwater, wetlands, or nearby properties.
Some communities require emergency stormwater disconnect systems at BESS facilities to protect downstream water resources.
Require a decommissioning bond similar to cellular phone towers or gravel pits, so costs to decommission BESS facilities do not fall on a community in the event the power company goes bankrupt or abandons the BESS facility due to reduced performance.
↓
BESS occasionally erupt into fire spontaneously when a thermal runaway event occurs. As of April 2023, the fire incident rate at l...↓arge-scale BESS facilities was 2.9%. The average age of BESS that caught fire was 18 months. Sources "Energy Storage Policy Database," Pacific Northwest National Laboratory, referenced by the University of Michigan, Ford School of Public Policy "Battery Energy Storage System Deployment: Local and State Policy Considerations" June 2024 white paper. In contrast, the estimated restaurant fire incident rate is .7%.
BESS fires are difficult to extinguish, may re-erupt after initial extinguishment, and may burn for multiple days before being finally brought under control.
Controlling BESS fires requires specialized training. Battery fires release toxic gases, but the primary risk of local environmental contamination is the use of water in fire suppression. Water binds to chemicals released during a BESS fire, which may contaminate groundwater, stormwater, wetlands, or nearby properties.
Some communities require emergency stormwater disconnect systems at BESS facilities to protect downstream water resources.
Require a decommissioning bond similar to cellular phone towers or gravel pits, so costs to decommission BESS facilities do not fall on a community in the event the power company goes bankrupt or abandons the BESS facility due to reduced performance.
↓
Attachments:
To the Department of Ecology, Clean Energy Coordination:
My name is Laurence Coleman and I live at 2203 234th Ave NE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium...↓-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live in a county with a proposed stand-alone BESS site, the Snoqualmie project, and my county's review of it will tier to this PEIS. My children attend school near a proposed stand-alone BESS site, at Snoqualmie middle school. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Laurence Coleman
2203 234th Ave NE↓
My name is Laurence Coleman and I live at 2203 234th Ave NE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium...↓-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live in a county with a proposed stand-alone BESS site, the Snoqualmie project, and my county's review of it will tier to this PEIS. My children attend school near a proposed stand-alone BESS site, at Snoqualmie middle school. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Laurence Coleman
2203 234th Ave NE↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Anne Williams and I live at 7729 Greenridge Ct SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithiu...↓m-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Anne Williams
7729 Greenridge Ct SE↓
My name is Anne Williams and I live at 7729 Greenridge Ct SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithiu...↓m-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Anne Williams
7729 Greenridge Ct SE↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Mann-Ling Thibert and I live at 7726 Douglas Ave SE, Snoqualmie, WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement (PEIS) for sta...↓nd-alone, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the latest code Washington actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation. PEIS should also evaluate the maximum limit allowed for economic losses in the community should the project fail
during any phase of the project. PEIS should evaluate and determine the size allowed on the container-based lithium-ion installations to be sized appropriately with the certain size and complexity of the community.
Q2 · Geographic scope — Where the study assumes batteries will go.
I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and just because it is close to a substation does not make it suitable.
Q3 · Impacts to analyze — The harms the study has to look at.
I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones. Review traffic impact caused by any nearby congested freeway or three-way intersection which is the major supply line from west to east coast.
Q4 · Mitigation — The steps Ecology should require for reducing the harm.
I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation, supply budget for effective extinguishing equipment and training for utility-scale, lithium-ion battery energy storage system facilities; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements. Ensure project accidents do not cause any long term or permanent harm to the community.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. All hazards and negative impacts by manmade projects rather than caused by mother nature should be prevented or minimized as much as possible prior to build. Therefore, I ask Ecology to thoroughly review the proposed BESS project and make sure the code is updated and relevant to the new BESS technology. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Mann-Ling Thibert
7726 Douglas Ave SE
Snoqualmie, WA 98065↓
My name is Mann-Ling Thibert and I live at 7726 Douglas Ave SE, Snoqualmie, WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement (PEIS) for sta...↓nd-alone, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the latest code Washington actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation. PEIS should also evaluate the maximum limit allowed for economic losses in the community should the project fail
during any phase of the project. PEIS should evaluate and determine the size allowed on the container-based lithium-ion installations to be sized appropriately with the certain size and complexity of the community.
Q2 · Geographic scope — Where the study assumes batteries will go.
I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and just because it is close to a substation does not make it suitable.
Q3 · Impacts to analyze — The harms the study has to look at.
I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones. Review traffic impact caused by any nearby congested freeway or three-way intersection which is the major supply line from west to east coast.
Q4 · Mitigation — The steps Ecology should require for reducing the harm.
I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation, supply budget for effective extinguishing equipment and training for utility-scale, lithium-ion battery energy storage system facilities; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements. Ensure project accidents do not cause any long term or permanent harm to the community.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. All hazards and negative impacts by manmade projects rather than caused by mother nature should be prevented or minimized as much as possible prior to build. Therefore, I ask Ecology to thoroughly review the proposed BESS project and make sure the code is updated and relevant to the new BESS technology. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Mann-Ling Thibert
7726 Douglas Ave SE
Snoqualmie, WA 98065↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Erin Linscott and I live at 36504 SE Isley St, Snoqualmie WA 98065, United States. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for st...↓and-alone, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Impacts to analyze — The harms the study has to look at.
Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Erin Linscott
36504 SE Isley St, Snoqualmie WA 98065, United States↓
My name is Erin Linscott and I live at 36504 SE Isley St, Snoqualmie WA 98065, United States. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for st...↓and-alone, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Impacts to analyze — The harms the study has to look at.
Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Erin Linscott
36504 SE Isley St, Snoqualmie WA 98065, United States↓
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To the Members of the Energy Facility Site Evaluation Council, I am writing to express my vehement and total opposition to the proposed Cascadia Ridge Battery Energy Storage System (BESS) project planned near Snoqualmie Ridge. Siting a massive, utili...↓ty-scale industrial lithium-ion energy storage facility in this specific location is an egregious threat to public health and safety. The project's proximity to dense residential neighborhoods, schools, medical facilities, and major recreational hubs—combined with severe infrastructure limitations—creates an unacceptable disaster waiting to happen.
1. Extreme Proximity to Vulnerable Populations and Critical Infrastructure:
The proposed site is dangerously close to major community assets where thousands of vulnerable citizens live, learn, work, and gather daily. It is situated less than a mile from several critical locations and within a two-mile radius of multiple elementary schools where hundreds of young children are concentrated here daily, representing a population uniquely vulnerable to toxic airborne hazards. A local Hospital and medical facilities: Facilities housing patients who cannot easily or rapidly self-evacuate in an emergency. A High-Density Commercial/Shopping Center which is a major hub for daily public commerce and gathering. Thousands of residential homes & a country club comprised of a densely populated community where thousands of families reside. Placing a high-risk industrial energy facility immediately adjacent to schools, healthcare centers, and thousands of homes violates basic principles of industrial land-use safety and human protection.
2. Catastrophic Evacuation Bottleneck (Single Point of Ingress/Egress):
Snoqualmie Ridge operates under severe geographic and infrastructure constraints—most notably, the extreme limitation of essentially having only one primary way in and one way out for thousands of residents. In the event of a catastrophic failure, thermal runaway, or explosion—which can release toxic, heavy, and immediately dangerous gases (such as hydrogen fluoride)—an emergency evacuation of the Ridge would face immediate, crippling gridlock. A mass evacuation order bottlenecked by a single primary thoroughfare would render orderly exit impossible. This dynamic transforms a localized industrial incident into a potential mass-casualty catastrophe, threatening the lives of thousands of residents, school children, and hospital patients, and ranking it among the most hazardous industrial land-use mismatches in the region's history.
3. Noise Pollution and Continuous Industrial Disruption:
In addition to catastrophic safety risks, the continuous operational noise pollution from heavy utility-scale cooling fans, inverters, and transformers will fundamentally degrade the quality of life and acoustic environment for nearby residential areas, the adjacent park-lands, and community spaces. Industrial decibel outputs and low-frequency tonal hums running continuously near family neighborhoods and schools violate the baseline expectations of a peaceful residential zone. The combination of high-density residential proximity, vulnerable public institutions (schools and hospitals), and a critically compromised single-access evacuation route makes this site fundamentally unsuited for a utility-scale BESS facility.I strongly urge the department to reject this site certification application outright, or at minimum, mandate a comprehensive, independent, worst-case-scenario Environmental Impact Statement (EIS) and toxic plume / evacuation modeling study that fully evaluates the catastrophic risk to human life on Snoqualmie Ridge. Anything less serves as a potential gross mismanagement of responsibility.
4. Financial Windfalls and Speculative Industrial Expansion Cannot Outweigh Public Safety:
I recognize the immense fiscal incentives and private capital driving this project. It is glaringly apparent that the push to place a utility-scale energy storage facility in such an inappropriate, high-density residential zone is driven by corporate financial interests, lucrative energy contracts, and potentially the speculative infrastructure needs of future heavy-power consumers, such as data centers. While this project will undoubtedly add zeros to the bank accounts of private developers and energy stakeholders, their financial gain cannot be subsidized by the safety, well-being, and property values of thousands of Snoqualmie Ridge residents. A clear-eyed view of this proposal reveals a profound imbalance: a handful of corporate entities reap the immense economic benefits, while our families, schools, and local infrastructure are forced to bear 100% of the catastrophic life-safety risks. Profit and industrial expansion must never outweigh the preservation of human life and community safety.↓
1. Extreme Proximity to Vulnerable Populations and Critical Infrastructure:
The proposed site is dangerously close to major community assets where thousands of vulnerable citizens live, learn, work, and gather daily. It is situated less than a mile from several critical locations and within a two-mile radius of multiple elementary schools where hundreds of young children are concentrated here daily, representing a population uniquely vulnerable to toxic airborne hazards. A local Hospital and medical facilities: Facilities housing patients who cannot easily or rapidly self-evacuate in an emergency. A High-Density Commercial/Shopping Center which is a major hub for daily public commerce and gathering. Thousands of residential homes & a country club comprised of a densely populated community where thousands of families reside. Placing a high-risk industrial energy facility immediately adjacent to schools, healthcare centers, and thousands of homes violates basic principles of industrial land-use safety and human protection.
2. Catastrophic Evacuation Bottleneck (Single Point of Ingress/Egress):
Snoqualmie Ridge operates under severe geographic and infrastructure constraints—most notably, the extreme limitation of essentially having only one primary way in and one way out for thousands of residents. In the event of a catastrophic failure, thermal runaway, or explosion—which can release toxic, heavy, and immediately dangerous gases (such as hydrogen fluoride)—an emergency evacuation of the Ridge would face immediate, crippling gridlock. A mass evacuation order bottlenecked by a single primary thoroughfare would render orderly exit impossible. This dynamic transforms a localized industrial incident into a potential mass-casualty catastrophe, threatening the lives of thousands of residents, school children, and hospital patients, and ranking it among the most hazardous industrial land-use mismatches in the region's history.
3. Noise Pollution and Continuous Industrial Disruption:
In addition to catastrophic safety risks, the continuous operational noise pollution from heavy utility-scale cooling fans, inverters, and transformers will fundamentally degrade the quality of life and acoustic environment for nearby residential areas, the adjacent park-lands, and community spaces. Industrial decibel outputs and low-frequency tonal hums running continuously near family neighborhoods and schools violate the baseline expectations of a peaceful residential zone. The combination of high-density residential proximity, vulnerable public institutions (schools and hospitals), and a critically compromised single-access evacuation route makes this site fundamentally unsuited for a utility-scale BESS facility.I strongly urge the department to reject this site certification application outright, or at minimum, mandate a comprehensive, independent, worst-case-scenario Environmental Impact Statement (EIS) and toxic plume / evacuation modeling study that fully evaluates the catastrophic risk to human life on Snoqualmie Ridge. Anything less serves as a potential gross mismanagement of responsibility.
4. Financial Windfalls and Speculative Industrial Expansion Cannot Outweigh Public Safety:
I recognize the immense fiscal incentives and private capital driving this project. It is glaringly apparent that the push to place a utility-scale energy storage facility in such an inappropriate, high-density residential zone is driven by corporate financial interests, lucrative energy contracts, and potentially the speculative infrastructure needs of future heavy-power consumers, such as data centers. While this project will undoubtedly add zeros to the bank accounts of private developers and energy stakeholders, their financial gain cannot be subsidized by the safety, well-being, and property values of thousands of Snoqualmie Ridge residents. A clear-eyed view of this proposal reveals a profound imbalance: a handful of corporate entities reap the immense economic benefits, while our families, schools, and local infrastructure are forced to bear 100% of the catastrophic life-safety risks. Profit and industrial expansion must never outweigh the preservation of human life and community safety.↓
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To the Department of Ecology, Clean Energy Coordination:
My name is Marcia Spani and I live at 35124 SE Kinsey St. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-io...↓n battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study should look at what a multi-day battery fire demands from local fire, hazmat, hospital, and evacuation capacity, since Ecology could not say whether the burden on small rural fire districts can be fixed. The study should properly model whether neighbors can evacuate without breathing dangerous levels of toxic gas in places such as a valley that traps air, which is what the fire code requires.
I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. The study should recommend large-scale fire testing be required for every facility, whether or not the state has adopted the newest code, since Ecology itself credits it with reducing risk. If harm from a BESS facility cannot be fixed, such as a fire that a small rural district cannot contain, the study should say so plainly and label it unavoidable. The study should state that local governments may require stronger protections than the state minimum. State standards should be a floor, not a ceiling.
I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Marcia Spani
35124 SE Kinsey St↓
My name is Marcia Spani and I live at 35124 SE Kinsey St. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-io...↓n battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study should look at what a multi-day battery fire demands from local fire, hazmat, hospital, and evacuation capacity, since Ecology could not say whether the burden on small rural fire districts can be fixed. The study should properly model whether neighbors can evacuate without breathing dangerous levels of toxic gas in places such as a valley that traps air, which is what the fire code requires.
I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. The study should recommend large-scale fire testing be required for every facility, whether or not the state has adopted the newest code, since Ecology itself credits it with reducing risk. If harm from a BESS facility cannot be fixed, such as a fire that a small rural district cannot contain, the study should say so plainly and label it unavoidable. The study should state that local governments may require stronger protections than the state minimum. State standards should be a floor, not a ceiling.
I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Marcia Spani
35124 SE Kinsey St↓
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To the Department of Ecology, Clean Energy Coordination:
My name is Neil Thibert and I live at 7726 Douglas Avenue SE, Snoqualmie, WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone,...↓ utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
The study should include large, container-based lithium-ion installations near residential areas. I would like the study to look at stand-alone sites near homes and neighborhoods, not the remote ones it studied before, since Ecology admits these sites are smaller and "could be sited in a variety of locations." The study should look at rows of container-sized battery boxes beside homes and schools, because that is what is being proposed and how Ecology itself describes these sites. The study should assume facilities would be built to the rules Washington has actually adopted, and say what the newest standards would change, since Ecology admits the state's fire code is behind them. I ask that Ecology define the facility types studied, and that the analysis assumes the fire codes currently in force in Washington, rely on independent safety data, and call for the newest safety standards as a condition of approval.
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Being near a substation should not make a place "suitable." Economics of construction should not replace safety. The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that Ecology not define "suitable" areas by grid proximity alone, and that the geographic-scope assumptions screen for nearby homes and schools, wildfire exposure, mapped seismic and flood hazards, private-well dependence, emergency vehicle access, availability of fire-fighting water, and limited evacuation routes.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Shelter-in-place is not an adequate response for a school when a fire can last for days. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the impact analysis cover battery-fire smoke and hydrogen fluoride under valley inversion conditions, fire-suppression runoff reaching wells and salmon streams, the load a multi-day incident puts on rural fire, HazMat, hospital, and evacuation capacity, all-night mechanical noise well past 1,000 feet, and how container-based facilities perform in an earthquake.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I would like the study to name specific, measurable protections a permit can require. Protections described "at a high level" give my county nothing to write into a permit. The study should be specific enough to give local reviewers something to hold a developer to, because my county will lean on it when it reviews a real project. The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. The study should recommend large-scale fire testing be required for every facility, whether or not the state has adopted the newest code, since Ecology itself credits it with reducing risk. I ask that Ecology name specific mitigation that lead agencies can adopt as permit conditions: real setbacks from homes, schools, and wells; UL 9540A testing and the current NFPA 855 edition; funded training and equipment for local responders before a facility operates; capture and disposal of fire-suppression water; nighttime noise limits measured at the nearest home; and decommissioning bonds.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Cascadia Ridge BESS project. My household depends on Douglas Avenue SE, which is also an emergency route for hundreds of homes and a school. I am a Licensed Civil Engineer, and I offer this comment with that professional background.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Neil Thibert
7726 Douglas Avenue SE
Snoqualmie, WA 98065
↓
My name is Neil Thibert and I live at 7726 Douglas Avenue SE, Snoqualmie, WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone,...↓ utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
The study should include large, container-based lithium-ion installations near residential areas. I would like the study to look at stand-alone sites near homes and neighborhoods, not the remote ones it studied before, since Ecology admits these sites are smaller and "could be sited in a variety of locations." The study should look at rows of container-sized battery boxes beside homes and schools, because that is what is being proposed and how Ecology itself describes these sites. The study should assume facilities would be built to the rules Washington has actually adopted, and say what the newest standards would change, since Ecology admits the state's fire code is behind them. I ask that Ecology define the facility types studied, and that the analysis assumes the fire codes currently in force in Washington, rely on independent safety data, and call for the newest safety standards as a condition of approval.
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Being near a substation should not make a place "suitable." Economics of construction should not replace safety. The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that Ecology not define "suitable" areas by grid proximity alone, and that the geographic-scope assumptions screen for nearby homes and schools, wildfire exposure, mapped seismic and flood hazards, private-well dependence, emergency vehicle access, availability of fire-fighting water, and limited evacuation routes.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Shelter-in-place is not an adequate response for a school when a fire can last for days. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the impact analysis cover battery-fire smoke and hydrogen fluoride under valley inversion conditions, fire-suppression runoff reaching wells and salmon streams, the load a multi-day incident puts on rural fire, HazMat, hospital, and evacuation capacity, all-night mechanical noise well past 1,000 feet, and how container-based facilities perform in an earthquake.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I would like the study to name specific, measurable protections a permit can require. Protections described "at a high level" give my county nothing to write into a permit. The study should be specific enough to give local reviewers something to hold a developer to, because my county will lean on it when it reviews a real project. The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. The study should recommend large-scale fire testing be required for every facility, whether or not the state has adopted the newest code, since Ecology itself credits it with reducing risk. I ask that Ecology name specific mitigation that lead agencies can adopt as permit conditions: real setbacks from homes, schools, and wells; UL 9540A testing and the current NFPA 855 edition; funded training and equipment for local responders before a facility operates; capture and disposal of fire-suppression water; nighttime noise limits measured at the nearest home; and decommissioning bonds.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Cascadia Ridge BESS project. My household depends on Douglas Avenue SE, which is also an emergency route for hundreds of homes and a school. I am a Licensed Civil Engineer, and I offer this comment with that professional background.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Neil Thibert
7726 Douglas Avenue SE
Snoqualmie, WA 98065
↓
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To the Department of Ecology, Clean Energy Coordination:
My name is Caitlin Quinn and I live at 7609 Orchard Ave SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-...↓ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
I would like to see the study thoroughly examine the direct, indirect, and cumulative effects of how smoke settles into valleys, runoff reaches wells and streams, and what happens when there are several facilities on the same stretch of grid. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Cascadia Ridge project. My household depends on Snoqualmie Parkway , which is also an emergency route for everyone along it. I am a Physical Therapist, and I offer this comment with that professional background.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Caitlin Quinn
7609 Orchard Ave SE↓
My name is Caitlin Quinn and I live at 7609 Orchard Ave SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-...↓ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
I would like to see the study thoroughly examine the direct, indirect, and cumulative effects of how smoke settles into valleys, runoff reaches wells and streams, and what happens when there are several facilities on the same stretch of grid. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Cascadia Ridge project. My household depends on Snoqualmie Parkway , which is also an emergency route for everyone along it. I am a Physical Therapist, and I offer this comment with that professional background.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Caitlin Quinn
7609 Orchard Ave SE↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Carlo Spani and I live at 35124 SE Kinsey St. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-ion...↓ battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
I would like the study to look at stand-alone sites near homes and neighborhoods, not the remote ones it studied before, since Ecology admits these sites are smaller and "could be sited in a variety of locations." The study should include the largest container-style installations now being proposed near neighborhoods, not just small substation batteries, since Ecology has not yet decided what kind of facility it will study. The study should picture rows of container-sized battery boxes beside homes and schools, because that is what is being proposed and how Ecology itself describes these sites. The study should assume facilities would be built to the rules Washington has actually adopted, and say what the newest standards would change, since Ecology admits the state's fire code is behind them. I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the code Washington has actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation.
Q2 · Geographic scope — Where the study assumes batteries will go.
I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Carlo Spani
35124 SE Kinsey St↓
My name is Carlo Spani and I live at 35124 SE Kinsey St. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-ion...↓ battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
I would like the study to look at stand-alone sites near homes and neighborhoods, not the remote ones it studied before, since Ecology admits these sites are smaller and "could be sited in a variety of locations." The study should include the largest container-style installations now being proposed near neighborhoods, not just small substation batteries, since Ecology has not yet decided what kind of facility it will study. The study should picture rows of container-sized battery boxes beside homes and schools, because that is what is being proposed and how Ecology itself describes these sites. The study should assume facilities would be built to the rules Washington has actually adopted, and say what the newest standards would change, since Ecology admits the state's fire code is behind them. I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the code Washington has actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation.
Q2 · Geographic scope — Where the study assumes batteries will go.
I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Carlo Spani
35124 SE Kinsey St↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Natalie Williams and I live at PMB 3682 POBox 257 Olympia WA 98507. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, util...↓ity-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
I ask that the impact analysis cover battery-fire smoke and hydrogen fluoride under valley inversion conditions, fire-suppression runoff reaching wells and salmon streams, the load a multi-day incident puts on rural fire, HazMat, hospital, and evacuation capacity, all-night mechanical noise well past 1,000 feet, and how container-based facilities perform in an earthquake.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I ask that Ecology name specific mitigation lead agencies can adopt as permit conditions: real setbacks from homes, schools, and wells; UL 9540A testing and the current NFPA 855 edition; funded training and equipment for local responders before a facility operates; capture and disposal of fire-suppression water; nighttime noise limits measured at the nearest home; and decommissioning bonds.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Cottages project.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Please protect our watershed.
Sincerely,
Natalie Williams
PMB 3682 POBox 257 Olympia WA 98507↓
My name is Natalie Williams and I live at PMB 3682 POBox 257 Olympia WA 98507. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, util...↓ity-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
I ask that the impact analysis cover battery-fire smoke and hydrogen fluoride under valley inversion conditions, fire-suppression runoff reaching wells and salmon streams, the load a multi-day incident puts on rural fire, HazMat, hospital, and evacuation capacity, all-night mechanical noise well past 1,000 feet, and how container-based facilities perform in an earthquake.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I ask that Ecology name specific mitigation lead agencies can adopt as permit conditions: real setbacks from homes, schools, and wells; UL 9540A testing and the current NFPA 855 edition; funded training and equipment for local responders before a facility operates; capture and disposal of fire-suppression water; nighttime noise limits measured at the nearest home; and decommissioning bonds.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Cottages project.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Please protect our watershed.
Sincerely,
Natalie Williams
PMB 3682 POBox 257 Olympia WA 98507↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Amy Pangborn and I live at 7716 Fairway Avenue Southeast, 801. I am writing to submit a comment on the Environmental Impact Statement for stand-alone, utility-scale, lithium-ion ba...↓ttery energy storage system facilities in Washington (Publication 26-06-017).
In the event of a system failure or runaway fire, please consider looking at the modeling for an inversion prone valley and/or wind prone Cascade foothills communities. Wind and inversions cannot be underestimated in establishing mitigation models.
How will the contaminated fire-suppression water be handled? What will be the path to groundwater, private wells, and fish-bearing streams; how will a multi-day incident add to demands on local fire, HazMat, hospital, and evacuation capacity?
How will evacuation be managed in a timely way so that residents are not sitting in the toxic smoke or fumes for hours as they try to exit schools or their community. Many communities have one entry and exit which bottlenecks at the slightest change in traffic accidents or road construction. An emergency of this potential would create a health hazard to the residents possibly sitting for hours in the toxic smoke and fumes.
Please consider proximity to residents and schools as a defining condition of the analysis. This potential impact MUST be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record.
Sincerely,
Amy Pangborn
7716 Fairway Avenue Southeast, 801↓
My name is Amy Pangborn and I live at 7716 Fairway Avenue Southeast, 801. I am writing to submit a comment on the Environmental Impact Statement for stand-alone, utility-scale, lithium-ion ba...↓ttery energy storage system facilities in Washington (Publication 26-06-017).
In the event of a system failure or runaway fire, please consider looking at the modeling for an inversion prone valley and/or wind prone Cascade foothills communities. Wind and inversions cannot be underestimated in establishing mitigation models.
How will the contaminated fire-suppression water be handled? What will be the path to groundwater, private wells, and fish-bearing streams; how will a multi-day incident add to demands on local fire, HazMat, hospital, and evacuation capacity?
How will evacuation be managed in a timely way so that residents are not sitting in the toxic smoke or fumes for hours as they try to exit schools or their community. Many communities have one entry and exit which bottlenecks at the slightest change in traffic accidents or road construction. An emergency of this potential would create a health hazard to the residents possibly sitting for hours in the toxic smoke and fumes.
Please consider proximity to residents and schools as a defining condition of the analysis. This potential impact MUST be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record.
Sincerely,
Amy Pangborn
7716 Fairway Avenue Southeast, 801↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Alona Petett and I live at 38002 SE Northern Street. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lith...↓ium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that Ecology not define "suitable" areas by grid proximity alone, and that the geographic-scope assumptions screen for nearby homes and schools, wildfire exposure, mapped seismic and flood hazards, private-well dependence, and limited evacuation routes.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them.
We live in a beautiful area and plan to take care of the land and resources to the best of our ability. I know there are other ways being developed for energy so put the resources into those and not into a plan that is in the process of becoming outdated before it is installed. I ask that the impact analysis cover battery-fire smoke and hydrogen fluoride under valley inversion conditions, fire-suppression runoff reaching wells and salmon streams, the load a multi-day incident puts on rural fire, HazMat, hospital, and evacuation capacity, all-night mechanical noise well past 1,000 feet, and how container-based facilities perform in an earthquake.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
The study should recommend developer-funded monitoring, cleanup guarantees, and decommissioning bonds, as state rules already require these for other energy facilities. The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My household depends on Railroad Ave / SR 202, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Alona Petett
38002 SE Northern Street↓
My name is Alona Petett and I live at 38002 SE Northern Street. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lith...↓ium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that Ecology not define "suitable" areas by grid proximity alone, and that the geographic-scope assumptions screen for nearby homes and schools, wildfire exposure, mapped seismic and flood hazards, private-well dependence, and limited evacuation routes.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them.
We live in a beautiful area and plan to take care of the land and resources to the best of our ability. I know there are other ways being developed for energy so put the resources into those and not into a plan that is in the process of becoming outdated before it is installed. I ask that the impact analysis cover battery-fire smoke and hydrogen fluoride under valley inversion conditions, fire-suppression runoff reaching wells and salmon streams, the load a multi-day incident puts on rural fire, HazMat, hospital, and evacuation capacity, all-night mechanical noise well past 1,000 feet, and how container-based facilities perform in an earthquake.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
The study should recommend developer-funded monitoring, cleanup guarantees, and decommissioning bonds, as state rules already require these for other energy facilities. The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My household depends on Railroad Ave / SR 202, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Alona Petett
38002 SE Northern Street↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Whitney Schrader and I live at 7722 Greenridge Ct Snoqualmie, WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, ...↓utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
I would like the study to look at stand-alone sites near homes and neighborhoods, not the remote ones it studied before, since Ecology admits these sites are smaller and "could be sited in a variety of locations." The study should include the largest container-style installations now being proposed near neighborhoods, not just small substation batteries, since Ecology has not yet decided what kind of facility it will study. The study should picture rows of container-sized battery boxes beside homes and schools, because that is what is being proposed and how Ecology itself describes these sites. The study should assume facilities would be built to the rules Washington has actually adopted, and say what the newest standards would change, since Ecology admits the state's fire code is behind them. The study should describe the safest current standard and treat it as the baseline for every facility, because safety rules vary from one local government to the next. The study should use independent safety data and count evacuations and cleanup as harms, not only fires, rather than relying on failure data from an industry-funded research institute. I ask that Ecology define the facility types studied to include large, container-based lithium-ion installations near residential areas, and that the analysis assume the fire codes currently in force in Washington, rely on independent safety data, and call for the newest safety standards as a condition of approval.
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. The study's geographic assumptions should screen out places with private wells, floodplains, earthquake faults, and neighborhoods with one road out, because site details will be left to later reviews. Wildfire exposure and fire-district capacity should be part of the map, since Ecology's own earlier studies flagged wildfire risk from "new ignition sources in remote locations with limited response capabilities." I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I would like the study to name specific, measurable protections a permit can require. Protections described "at a high level" give my county nothing to write into a permit. The study should be specific enough to give local reviewers something to hold a developer to, because my county will lean on it when it reviews a real project. The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. The study should recommend large-scale fire testing be required for every facility, whether or not the state has adopted the newest code, since Ecology itself credits it with reducing risk. The study should detail what it would take to reduce wildfire and fire-response harms, including funded training and equipment for local responders before a facility opens, since Ecology's earlier studies could not say whether they can be reduced enough. If harm from a BESS facility cannot be fixed, such as a fire that a small rural district cannot contain, the study should say so plainly and label it unavoidable. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Cascadia Ridge project. My children attend school near a proposed stand-alone BESS site. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Whitney Schrader
7722 Greenridge Ct Snoqualmie, WA 98065↓
My name is Whitney Schrader and I live at 7722 Greenridge Ct Snoqualmie, WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, ...↓utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
I would like the study to look at stand-alone sites near homes and neighborhoods, not the remote ones it studied before, since Ecology admits these sites are smaller and "could be sited in a variety of locations." The study should include the largest container-style installations now being proposed near neighborhoods, not just small substation batteries, since Ecology has not yet decided what kind of facility it will study. The study should picture rows of container-sized battery boxes beside homes and schools, because that is what is being proposed and how Ecology itself describes these sites. The study should assume facilities would be built to the rules Washington has actually adopted, and say what the newest standards would change, since Ecology admits the state's fire code is behind them. The study should describe the safest current standard and treat it as the baseline for every facility, because safety rules vary from one local government to the next. The study should use independent safety data and count evacuations and cleanup as harms, not only fires, rather than relying on failure data from an industry-funded research institute. I ask that Ecology define the facility types studied to include large, container-based lithium-ion installations near residential areas, and that the analysis assume the fire codes currently in force in Washington, rely on independent safety data, and call for the newest safety standards as a condition of approval.
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. The study's geographic assumptions should screen out places with private wells, floodplains, earthquake faults, and neighborhoods with one road out, because site details will be left to later reviews. Wildfire exposure and fire-district capacity should be part of the map, since Ecology's own earlier studies flagged wildfire risk from "new ignition sources in remote locations with limited response capabilities." I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I would like the study to name specific, measurable protections a permit can require. Protections described "at a high level" give my county nothing to write into a permit. The study should be specific enough to give local reviewers something to hold a developer to, because my county will lean on it when it reviews a real project. The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. The study should recommend large-scale fire testing be required for every facility, whether or not the state has adopted the newest code, since Ecology itself credits it with reducing risk. The study should detail what it would take to reduce wildfire and fire-response harms, including funded training and equipment for local responders before a facility opens, since Ecology's earlier studies could not say whether they can be reduced enough. If harm from a BESS facility cannot be fixed, such as a fire that a small rural district cannot contain, the study should say so plainly and label it unavoidable. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Cascadia Ridge project. My children attend school near a proposed stand-alone BESS site. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Whitney Schrader
7722 Greenridge Ct Snoqualmie, WA 98065↓
No attachments
The Snoqualmie Valley is a very special place to live and work and it is the ancestral home of the Snoqualmie Indian Tribe. It's natural beauty is unparalleled and it should be preserved, without exception, for future generations. This project is t...↓oo close to residential areas and too risky for an area this pristine.
I will not list all of the potential drawbacks to this project as I would only be re-stating what has already been said. We all know that there is not upside for residents and that projects of this kind harm communities. The bottom line is that there must be another area that would be better suited. What other areas still need to be explored? This is now a state issue so shouldn't the entire state be considered? Why build here when the community is completely opposed to it?↓
I will not list all of the potential drawbacks to this project as I would only be re-stating what has already been said. We all know that there is not upside for residents and that projects of this kind harm communities. The bottom line is that there must be another area that would be better suited. What other areas still need to be explored? This is now a state issue so shouldn't the entire state be considered? Why build here when the community is completely opposed to it?↓
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To the Department of Ecology, Clean Energy Coordination:
My name is Amber Spady and I live in a Washington community where there is currently a proposed battery facility. I am writing to submit a scoping comment on the Programmatic Environmental Imp...↓act Statement for stand-alone, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I would like the study to name specific, measurable protections a permit can require. Protections described "at a high level" give my county nothing to write into a permit. The study should be specific enough to give local reviewers something to hold a developer to, because my county will lean on it when it reviews a real project. The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. The study should recommend large-scale fire testing be required for every facility, whether or not the state has adopted the newest code, since Ecology itself credits it with reducing risk. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live in a county with a proposed stand-alone BESS site, the Jupiter Power project, and my county's review of it will tier to this PEIS. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Amber Spady↓
My name is Amber Spady and I live in a Washington community where there is currently a proposed battery facility. I am writing to submit a scoping comment on the Programmatic Environmental Imp...↓act Statement for stand-alone, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I would like the study to name specific, measurable protections a permit can require. Protections described "at a high level" give my county nothing to write into a permit. The study should be specific enough to give local reviewers something to hold a developer to, because my county will lean on it when it reviews a real project. The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. The study should recommend large-scale fire testing be required for every facility, whether or not the state has adopted the newest code, since Ecology itself credits it with reducing risk. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live in a county with a proposed stand-alone BESS site, the Jupiter Power project, and my county's review of it will tier to this PEIS. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Amber Spady↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Alex Wunderlich and I live at 39735 SE Walnut Street, Snoqualmie, WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alo...↓ne, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. We must consider the potential impact to nearby communities, including dangers to humans and the ecosystem. These facilities are a disaster waiting to happen, and they should not be forced on communities (often against their will) without thorough research, risk mitigation, and consideration of alternatives. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. We cannot fail to consider the impact to nearby residents (and wildlife). I'll reiterate that these facilities are a disaster waiting to happen, and they should not be forced on communities (often against their will) without thorough research, risk mitigation, and consideration of alternatives. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Cascadia Ridge Resiliency Energy Storage facility project. My household depends on Meadowbrook Way / Boalch Ave, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Alex Wunderlich
39735 SE Walnut St, Snoqualmie, WA 98065↓
My name is Alex Wunderlich and I live at 39735 SE Walnut Street, Snoqualmie, WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alo...↓ne, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. We must consider the potential impact to nearby communities, including dangers to humans and the ecosystem. These facilities are a disaster waiting to happen, and they should not be forced on communities (often against their will) without thorough research, risk mitigation, and consideration of alternatives. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. We cannot fail to consider the impact to nearby residents (and wildlife). I'll reiterate that these facilities are a disaster waiting to happen, and they should not be forced on communities (often against their will) without thorough research, risk mitigation, and consideration of alternatives. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Cascadia Ridge Resiliency Energy Storage facility project. My household depends on Meadowbrook Way / Boalch Ave, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Alex Wunderlich
39735 SE Walnut St, Snoqualmie, WA 98065↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Matthew Gray and I live at 10826 428th Ave SE, North Bend, WA 98045. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, uti...↓lity-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
I would like the study to look at stand-alone sites near homes and neighborhoods, not just the remote ones it has studied before, since its not about size but the potential for harm from a number of different sources and failures. The study should include all container-style installations being proposed since Ecology has not yet fully understand the potential harm and be consistent across the state. The study should pictures of all potential situations including container-sized battery boxes beside homes and schools to support Ecologies descriptions of sites. The study should assume facilities would be built to the rules Washington has actually adopted similar to other development rules and regulations such as development in floodplains, stormwater, wetlands, and state that any updates will immediately be included similar to road and stormwater standards adopted by other state agencies. The study should use independent safety data and count evacuations and cleanup as harms, not only fires, rather than relying on failure data from an industry-funded research institute. I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the code Washington has actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation.
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis prior to application to fully understand possible impacts similar to how new technologies are evaluated prior to implementation. It's important that the study model what a battery fire's smoke does to the people living nearby and downwind. The scoping document acknowledges toxic gas from damaged batteries can damage firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not even be aware of the event. Evacuation, displacement, and offsite cleanup should be included in evaluating impacts. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. The study should look at what a multi-day battery fire demands from local fire, hazmat, hospital, and evacuation capacity, since Ecology could not say whether the burden on small rural fire districts can be fixed. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I would like the study to name specific, measurable protections a permit can require. Standards need to be quantified so that they can hold developers to standards and permit writers don't have to guess. The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, streams, parks, and drinking-water wells that are proven to be safe for the surrounding community. The study should recommend large-scale fire testing be required for every facility, whether or not the state has adopted the newest code, since Ecology itself credits it with reducing risk. The study should detail what it would take to reduce wildfire and fire-response harms, including funded training and equipment for local responders before a facility opens, since Ecology's earlier studies could not say whether they can be reduced enough. If harm from a BESS facility cannot be fixed, such as a fire that a small rural district cannot contain, the study should say so plainly and label it unavoidable. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live downwind of a proposed stand-alone BESS site, in the same air basin, fire district, and hospital service area.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Matthew Gray
10826 428th Ave SE, North Bend, WA 98045↓
My name is Matthew Gray and I live at 10826 428th Ave SE, North Bend, WA 98045. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, uti...↓lity-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
I would like the study to look at stand-alone sites near homes and neighborhoods, not just the remote ones it has studied before, since its not about size but the potential for harm from a number of different sources and failures. The study should include all container-style installations being proposed since Ecology has not yet fully understand the potential harm and be consistent across the state. The study should pictures of all potential situations including container-sized battery boxes beside homes and schools to support Ecologies descriptions of sites. The study should assume facilities would be built to the rules Washington has actually adopted similar to other development rules and regulations such as development in floodplains, stormwater, wetlands, and state that any updates will immediately be included similar to road and stormwater standards adopted by other state agencies. The study should use independent safety data and count evacuations and cleanup as harms, not only fires, rather than relying on failure data from an industry-funded research institute. I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the code Washington has actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation.
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis prior to application to fully understand possible impacts similar to how new technologies are evaluated prior to implementation. It's important that the study model what a battery fire's smoke does to the people living nearby and downwind. The scoping document acknowledges toxic gas from damaged batteries can damage firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not even be aware of the event. Evacuation, displacement, and offsite cleanup should be included in evaluating impacts. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. The study should look at what a multi-day battery fire demands from local fire, hazmat, hospital, and evacuation capacity, since Ecology could not say whether the burden on small rural fire districts can be fixed. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I would like the study to name specific, measurable protections a permit can require. Standards need to be quantified so that they can hold developers to standards and permit writers don't have to guess. The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, streams, parks, and drinking-water wells that are proven to be safe for the surrounding community. The study should recommend large-scale fire testing be required for every facility, whether or not the state has adopted the newest code, since Ecology itself credits it with reducing risk. The study should detail what it would take to reduce wildfire and fire-response harms, including funded training and equipment for local responders before a facility opens, since Ecology's earlier studies could not say whether they can be reduced enough. If harm from a BESS facility cannot be fixed, such as a fire that a small rural district cannot contain, the study should say so plainly and label it unavoidable. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live downwind of a proposed stand-alone BESS site, in the same air basin, fire district, and hospital service area.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Matthew Gray
10826 428th Ave SE, North Bend, WA 98045↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Anastasia Ivasenko and I live at 6720 Silent Creek Ave SE Snoqualmie, WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone...↓, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. The study's geographic assumptions should screen out places with private wells, floodplains, earthquake faults, and neighborhoods with one road out, because site details will be left to later reviews. Ecology promised to hear from local communities and it's important to take what our communities are saying about where we live seriously in order to ensure this study is done properly. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. I would like to see the study thoroughly examine the direct, indirect, and cumulative effects of how smoke settles into valleys, runoff reaches wells and streams, and what happens when there are several facilities on the same stretch of grid. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My children attend school near a proposed stand-alone BESS site. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Anastasia Ivasenko
6720 Silent Creek Ave SE Snoqualmie, WA↓
My name is Anastasia Ivasenko and I live at 6720 Silent Creek Ave SE Snoqualmie, WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone...↓, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. The study's geographic assumptions should screen out places with private wells, floodplains, earthquake faults, and neighborhoods with one road out, because site details will be left to later reviews. Ecology promised to hear from local communities and it's important to take what our communities are saying about where we live seriously in order to ensure this study is done properly. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. I would like to see the study thoroughly examine the direct, indirect, and cumulative effects of how smoke settles into valleys, runoff reaches wells and streams, and what happens when there are several facilities on the same stretch of grid. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My children attend school near a proposed stand-alone BESS site. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Anastasia Ivasenko
6720 Silent Creek Ave SE Snoqualmie, WA↓
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My name is Cristie Coffing. I live at 8054 Maple Ave SE, Snoqualmie. I will be directly affected by the proposed BESS project. The following has been noted in other studies regarding similar facilities. I hope you will study the environmental effects...↓ thoroughly.
- environmental effects are proven to be disastrous if a fire or a leak occurs
- the noise is detrimental to habitat species and humans
- the project is located in close proximity to a playground and homes
- the watershed and river are at risk of contamination
This is a poor choice of location.
Thank you for your consideration.
Cristie Coffing
↓
- environmental effects are proven to be disastrous if a fire or a leak occurs
- the noise is detrimental to habitat species and humans
- the project is located in close proximity to a playground and homes
- the watershed and river are at risk of contamination
This is a poor choice of location.
Thank you for your consideration.
Cristie Coffing
↓
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To the Department of Ecology, Clean Energy Coordination:
My name is Deborah Jarvi and I live at 7421 Warren Ave Se, Unit B, Snoqualmie WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-al...↓one, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Building these types of facilities in locations where homes, schools, hospitals, etc. are in evacuation or shelter in place zones is not acceptable. Also, evacuation routes need to be studied, clearly defined and determined to be adequate for the affected population. The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Snoqualmie project. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Deborah Jarvi
7421 Warren Ave Se, Unit B, Snoqualmie WA 98065↓
My name is Deborah Jarvi and I live at 7421 Warren Ave Se, Unit B, Snoqualmie WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-al...↓one, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Building these types of facilities in locations where homes, schools, hospitals, etc. are in evacuation or shelter in place zones is not acceptable. Also, evacuation routes need to be studied, clearly defined and determined to be adequate for the affected population. The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Snoqualmie project. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Deborah Jarvi
7421 Warren Ave Se, Unit B, Snoqualmie WA 98065↓
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To the Department of Ecology, Clean Energy Coordination:
My name is Maggie Carrido Adams and I live at 36532 SE Woody Creek Lane. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-sc...↓ale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
The study should be specific enough to give local reviewers something to hold a developer to, because my county will lean on it when it reviews a real project. The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. The study should recommend large-scale fire testing be required for every facility, whether or not the state has adopted the newest code, since Ecology itself credits it with reducing risk. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My household depends on Highway 18 and SR202, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Maggie Carrido Adams
36532 SE Woody Creek Lane↓
My name is Maggie Carrido Adams and I live at 36532 SE Woody Creek Lane. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-sc...↓ale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
The study should be specific enough to give local reviewers something to hold a developer to, because my county will lean on it when it reviews a real project. The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. The study should recommend large-scale fire testing be required for every facility, whether or not the state has adopted the newest code, since Ecology itself credits it with reducing risk. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My household depends on Highway 18 and SR202, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Maggie Carrido Adams
36532 SE Woody Creek Lane↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-ion battery energy storage system facilities in Washington (...↓Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live downstream or downwind of a proposed stand-alone BESS site, in the same air basin, fire district, and hospital service area.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Ava Boeker
39735 SE Walnut Street↓
I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-ion battery energy storage system facilities in Washington (...↓Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live downstream or downwind of a proposed stand-alone BESS site, in the same air basin, fire district, and hospital service area.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Ava Boeker
39735 SE Walnut Street↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Melody Correia and I live at 6535 Fairway Ave, SE, Snoqualmie WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, ...↓utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
The study should assume facilities would be built to the rules Washington has actually adopted, and say what the newest standards would change, since Ecology admits the state's fire code is behind them. I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the code Washington has actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation.
Q2 · Geographic scope — Where the study assumes batteries will go.
The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. In the case of Cascadia Ridge, there are multiple facilities that serve thousands of children per week just a few hundred feet away, those include Sno-King, a skating facility that hosts over 500 children on a daily basis 7 days a week. As well as a church daycare and preschool at Church on the Ridge that has well over 100 babies, toddlers and pre school-aged children. Not to mention over 1,000 students being educated between the Timber Ridge and Cascade View Elementary schools who will need to be sheltered in place or evacuated and will have their education interrupted if there is an event at this facility. Being very familiar with both schools, the church and the skating rink, none of these facilities have the ability to filter out toxins from a fire nor would they have adequate emergency planning to shelter these children in place nor means to quickly evacuate the children.
I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Cascadia Ridge project. My child attends a school near a proposed stand-alone BESS site, at Cascade View Elementary School, he skates at Sno-King, he went to Sunday school at Church on the Ridge. My household depends on Snoqualmie Parkway for evacuation, which is also an emergency route for everyone along it and many people in the valley.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Melody Correia
6535 Fairway Ave, SE, Snoqualmie WA 98065↓
My name is Melody Correia and I live at 6535 Fairway Ave, SE, Snoqualmie WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, ...↓utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
The study should assume facilities would be built to the rules Washington has actually adopted, and say what the newest standards would change, since Ecology admits the state's fire code is behind them. I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the code Washington has actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation.
Q2 · Geographic scope — Where the study assumes batteries will go.
The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. In the case of Cascadia Ridge, there are multiple facilities that serve thousands of children per week just a few hundred feet away, those include Sno-King, a skating facility that hosts over 500 children on a daily basis 7 days a week. As well as a church daycare and preschool at Church on the Ridge that has well over 100 babies, toddlers and pre school-aged children. Not to mention over 1,000 students being educated between the Timber Ridge and Cascade View Elementary schools who will need to be sheltered in place or evacuated and will have their education interrupted if there is an event at this facility. Being very familiar with both schools, the church and the skating rink, none of these facilities have the ability to filter out toxins from a fire nor would they have adequate emergency planning to shelter these children in place nor means to quickly evacuate the children.
I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Cascadia Ridge project. My child attends a school near a proposed stand-alone BESS site, at Cascade View Elementary School, he skates at Sno-King, he went to Sunday school at Church on the Ridge. My household depends on Snoqualmie Parkway for evacuation, which is also an emergency route for everyone along it and many people in the valley.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Melody Correia
6535 Fairway Ave, SE, Snoqualmie WA 98065↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Elizabeth Vaughan and I live at 34821 SE Burrows Way, Snoqualmie WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alon...↓e, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
Responder training, hard-to-extinguish fires, toxic air, harm to wildlife (incl. fish), water and cleanup each get a full analysis, as the Ecology study scoping document states it "will evaluate" each of them. The study must model what a battery fire's smoke does to the people and wildlife, living and migrating nearby. The scoping document acknowledges potential harm to firefighters' skin and lungs but does not mention neighbors, who lack protective gear and may not be able to leave. Nor are lingering impacts to water and wildlife considered. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. The Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. The study should look at what a multi-day battery fire demands from local fire, hazmat, hospital, and evacuation capacity, since Ecology could not say whether the burden on small rural fire districts can be fixed. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Cascadia Ridge project. My household depends on SR 18 and Railroad Ave (SR202), which are emergency routes for everyone along them.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Elizabeth Vaughan
34821 SE Burrows Way, Snoqualmie WA 98065↓
My name is Elizabeth Vaughan and I live at 34821 SE Burrows Way, Snoqualmie WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alon...↓e, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
Responder training, hard-to-extinguish fires, toxic air, harm to wildlife (incl. fish), water and cleanup each get a full analysis, as the Ecology study scoping document states it "will evaluate" each of them. The study must model what a battery fire's smoke does to the people and wildlife, living and migrating nearby. The scoping document acknowledges potential harm to firefighters' skin and lungs but does not mention neighbors, who lack protective gear and may not be able to leave. Nor are lingering impacts to water and wildlife considered. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. The Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. The study should look at what a multi-day battery fire demands from local fire, hazmat, hospital, and evacuation capacity, since Ecology could not say whether the burden on small rural fire districts can be fixed. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Cascadia Ridge project. My household depends on SR 18 and Railroad Ave (SR202), which are emergency routes for everyone along them.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Elizabeth Vaughan
34821 SE Burrows Way, Snoqualmie WA 98065↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Hannah Prall and I live in Snoqualmie, WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-ion ba...↓ttery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
It's important that the study models what a battery fire's smoke does to the people living nearby based on the regional conditions for that area. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. It is also should be explicitly stated that environmental conditions should be factored into the safety studies. I live in an area with high winds so standard safety testing does not take into account the effects of 40mph winds on fires and smoke dispersion. Washington's unique terrain leads to environmental challenges and geographic constraints (mountains, wind, limited access to towns, etc.) that will impact first responder and citizens' safety in event of a runaway battery event. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Hannah Prall
7405 Dogwood Ln SE, Snoqualmie, WA↓
My name is Hannah Prall and I live in Snoqualmie, WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-ion ba...↓ttery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
It's important that the study models what a battery fire's smoke does to the people living nearby based on the regional conditions for that area. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. It is also should be explicitly stated that environmental conditions should be factored into the safety studies. I live in an area with high winds so standard safety testing does not take into account the effects of 40mph winds on fires and smoke dispersion. Washington's unique terrain leads to environmental challenges and geographic constraints (mountains, wind, limited access to towns, etc.) that will impact first responder and citizens' safety in event of a runaway battery event. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Hannah Prall
7405 Dogwood Ln SE, Snoqualmie, WA↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Bryan Keller and I live at 6511 W Crest View Loop SE, Snoqualmie, WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alo...↓ne, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. I live in Snoqualmie, about 1 mile from the proposed site, and I oppose siting large lithium battery facilities in communities like ours. I ask that the programmatic EIS address the following. Do not treat valleys like ours as "suitable" by default. The study should weigh valley terrain that traps smoke, floodplains, wildfire-urban interface zones, limited evacuation routes, and distance from schools. Set minimum setbacks from schools and homes based on smoke modeling rather than noise alone. I ask that Ecology not define "suitable" areas by grid proximity alone, and that the geographic-scope assumptions screen for nearby homes and schools, wildfire exposure, mapped seismic and flood hazards, private-well dependence, and limited evacuation routes.
Q3 · Impacts to analyze — The harms the study has to look at.
Analyze worst-case thermal runaway events, not just typical failures. The Moss Landing fire in January 2025 burned for days and forced evacuations. Model how toxic smoke, including hydrogen fluoride, would travel and settle in a narrow valley prone to temperature inversions, and what that means for schools, homes, and outdoor activities within several miles. Study contamination of groundwater and the Snoqualmie River from firefighting runoff. Assess whether rural fire districts have the equipment, training, and water supply to respond, and how long mutual aid would take to arrive. Include a socioeconomic analysis of impacts on nearby property values. I ask that the impact analysis cover battery-fire smoke and hydrogen fluoride under valley inversion conditions, fire-suppression runoff reaching wells and salmon streams, the load a multi-day incident puts on rural fire, HazMat, hospital, and evacuation capacity, all-night mechanical noise well past 1,000 feet, and how container-based facilities perform in an earthquake.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the BESS Snoqualmie Fischer Creek project. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Bryan Keller
6511 W Crest View Loop SE, Snoqualmie, WA 98064↓
My name is Bryan Keller and I live at 6511 W Crest View Loop SE, Snoqualmie, WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alo...↓ne, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. I live in Snoqualmie, about 1 mile from the proposed site, and I oppose siting large lithium battery facilities in communities like ours. I ask that the programmatic EIS address the following. Do not treat valleys like ours as "suitable" by default. The study should weigh valley terrain that traps smoke, floodplains, wildfire-urban interface zones, limited evacuation routes, and distance from schools. Set minimum setbacks from schools and homes based on smoke modeling rather than noise alone. I ask that Ecology not define "suitable" areas by grid proximity alone, and that the geographic-scope assumptions screen for nearby homes and schools, wildfire exposure, mapped seismic and flood hazards, private-well dependence, and limited evacuation routes.
Q3 · Impacts to analyze — The harms the study has to look at.
Analyze worst-case thermal runaway events, not just typical failures. The Moss Landing fire in January 2025 burned for days and forced evacuations. Model how toxic smoke, including hydrogen fluoride, would travel and settle in a narrow valley prone to temperature inversions, and what that means for schools, homes, and outdoor activities within several miles. Study contamination of groundwater and the Snoqualmie River from firefighting runoff. Assess whether rural fire districts have the equipment, training, and water supply to respond, and how long mutual aid would take to arrive. Include a socioeconomic analysis of impacts on nearby property values. I ask that the impact analysis cover battery-fire smoke and hydrogen fluoride under valley inversion conditions, fire-suppression runoff reaching wells and salmon streams, the load a multi-day incident puts on rural fire, HazMat, hospital, and evacuation capacity, all-night mechanical noise well past 1,000 feet, and how container-based facilities perform in an earthquake.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the BESS Snoqualmie Fischer Creek project. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Bryan Keller
6511 W Crest View Loop SE, Snoqualmie, WA 98064↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Cheri Myers. I live in Snoqualmie WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-ion battery...↓ energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land could have a facility built on it. Conditions like those in the Snoqualmie Valley should be part of what the study considers. Wildfire exposure and fire-district capacity should also be part of where facilities can be built, since Ecology's own earlier studies flagged wildfire risk from "new ignition sources in remote locations with limited response capabilities" as a problem. Ecology has promised to hear from local communities. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
I live near a site where a stand-alone BESS facility is proposed, the Cascadia Ridge BESS project - making this personal for my household. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it. Please take what our communities are saying seriously about where we live and what needs to be assessed in order to ensure this study is done properly.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Cheri Myers
34426 SE Hall, Snoqualmie WA↓
My name is Cheri Myers. I live in Snoqualmie WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-ion battery...↓ energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land could have a facility built on it. Conditions like those in the Snoqualmie Valley should be part of what the study considers. Wildfire exposure and fire-district capacity should also be part of where facilities can be built, since Ecology's own earlier studies flagged wildfire risk from "new ignition sources in remote locations with limited response capabilities" as a problem. Ecology has promised to hear from local communities. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
I live near a site where a stand-alone BESS facility is proposed, the Cascadia Ridge BESS project - making this personal for my household. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it. Please take what our communities are saying seriously about where we live and what needs to be assessed in order to ensure this study is done properly.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Cheri Myers
34426 SE Hall, Snoqualmie WA↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Charles Bills and I live at 34426 SE Hall St.. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-io...↓n battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Water availability is a key factor in deciding where to site these facilities, as numerous BESS fire incidents have demonstrated that suppressing thermal runaway requires water flow rates exceeding 5,000 liters per minute. The Snoqualmie Valley, for instance, has severely constrained water resources that are steadily diminishing because of climate change. And providing water at that rate would impair the city's ability to provide water for its citizens.
I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Charles Bills
34426 SE Hall St.
↓
My name is Charles Bills and I live at 34426 SE Hall St.. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-io...↓n battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Water availability is a key factor in deciding where to site these facilities, as numerous BESS fire incidents have demonstrated that suppressing thermal runaway requires water flow rates exceeding 5,000 liters per minute. The Snoqualmie Valley, for instance, has severely constrained water resources that are steadily diminishing because of climate change. And providing water at that rate would impair the city's ability to provide water for its citizens.
I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Charles Bills
34426 SE Hall St.
↓
No attachments
To the SEPA Responsible Official and BESS PEIS Scoping Team:
I am submitting these scoping comments regarding the development of the Programmatic Environmental Impact Statement (PEIS) for Battery Energy Storage Systems (Publication 26-06-017).
Whil...↓e the PEIS is intended to streamline clean energy deployment, an environmental review that analyzes battery hazards in isolation will inadvertently protect incumbent fossil fuel generation. Utility-scale energy storage is the direct technological replacement for fossil-fueled peaker plants. If this PEIS establishes broad, duplicative hurdles, treats all battery technologies as having uniform thermal hazards, or evaluates storage without comparing it to fossil baselines, it will delay grid decarbonization and entrench fossil assets, contrary to the Clean Energy Transformation Act (CETA).
To ensure an accurate, technology-inclusive, and legally defensible scope under SEPA, I request that Ecology incorporate the following requirements into the final PEIS:
1. Differentiate Next-Generation Chemistries with Negligible Thermal Hazards
Ecology must not treat "BESS" as synonymous with legacy, first-generation lithium-ion configurations. Siting, setback, and fire suppression mitigation measures must not be applied as blanket mandates across vastly different cell chemistries.
Sodium-Ion (Na-ion): Rapidly entering utility-scale commercialization, sodium-ion cells exhibit significantly higher thermal stability, lower risk of thermal runaway, and can be transported and stored at 0 volts (zero state of charge), practically eliminating transport and construction hazard baselines.
Iron-Air and Aqueous/Flow Chemistries: Long-duration storage systems—such as iron-air and non-flammable flow batteries—operate using water-based electrolytes with virtually zero risk of fire propagation or toxic deflagration gas release.
Tiered Regulatory Pathways: The PEIS must establish tiered mitigation frameworks where inherently safe, non-propagating, or low-fire-risk chemistries qualify for expedited, minimal SEPA review rather than being forced into the heavy mitigation envelopes designed for older chemistries.
2. Mandate an "Avoided Fossil Emissions" Lifecycle Baseline
Under SEPA, the environmental impact of non-emitting grid infrastructure must be measured against real-world grid operations:
The PEIS must quantitatively model the net displaced emissions achieved by energy storage, including avoided greenhouse gases, upstream methane leakage, and localized criteria pollutants (\text{NO}_x, VOCs, and PM2.5) that occur when gas peakers dispatch during peak demand.
The PEIS must not evaluate worst-case, low-probability localized incidents (e.g., thermal runaway or fire water runoff) without directly weighting those risks against the known, continuous public health and environmental damage of fossil fuel combustion.
3. Accurately Model the Environmental Damage of the "No Action Alternative"
Treating the "No Action Alternative" as an environmentally benign baseline is factually flawed:
In the Northwest power grid, failing to deploy adequate utility-scale storage requires maintaining, running, and extending the operational lives of fossil-fueled generation to satisfy resource adequacy requirements.
The PEIS must explicitly state that the "No Action Alternative" prolongs fossil reliance, increases long-term regional carbon intensity, and directly impedes compliance with Washington's statutory decarbonization mandates.
4. Ensure the PEIS Serves as a Streamlining Mitigation Menu, Not a Moratorium Tool
Across the Pacific Northwest, open-ended environmental review processes are routinely co-opted at the municipal and county levels to justify blanket moratoria or arbitrary Special Use Permit denials under the premise of "waiting for state guidance."
The PEIS must be explicitly defined as a non-mandatory, non-exclusive mitigation menu designed to help local lead agencies rapidly complete project-level SEPA checklists.
For projects sited in appropriate areas—such as industrial zones, brownfields, or land immediately adjacent to existing electrical substations (where fossil peakers have traditionally operated)—the PEIS should provide streamlined, categorical evaluation paths.
5. Ground Hazard Assessments in Modern Design Codes (NFPA 855 / UL 9540A)
For chemistries where thermal hazards are present, safety assessments must reflect current code-compliant engineering rather than legacy failures:
Evaluations must assume compliance with modern standards including NFPA 855, UL 9540, and UL 9540A testing, which require unit-level separation, gas detection, deflagration venting, and multi-tier Battery Management Systems (BMS).
Risk modeling must account for standard utility adoption of Lithium Iron Phosphate (LFP) over older Nickel Manganese Cobalt (NMC) chemistries, reflecting LFP's higher thermal stability and resistance to self-sustaining fire.
Ecology must ensure this PEIS fulfills its mandate: accelerating the safe, timely, and rational transition to a zero-emissions grid, rather than giving incumbent fossil generation a procedural shield against clean storage competition.
Thank you for your consideration of these scoping comments.↓
I am submitting these scoping comments regarding the development of the Programmatic Environmental Impact Statement (PEIS) for Battery Energy Storage Systems (Publication 26-06-017).
Whil...↓e the PEIS is intended to streamline clean energy deployment, an environmental review that analyzes battery hazards in isolation will inadvertently protect incumbent fossil fuel generation. Utility-scale energy storage is the direct technological replacement for fossil-fueled peaker plants. If this PEIS establishes broad, duplicative hurdles, treats all battery technologies as having uniform thermal hazards, or evaluates storage without comparing it to fossil baselines, it will delay grid decarbonization and entrench fossil assets, contrary to the Clean Energy Transformation Act (CETA).
To ensure an accurate, technology-inclusive, and legally defensible scope under SEPA, I request that Ecology incorporate the following requirements into the final PEIS:
1. Differentiate Next-Generation Chemistries with Negligible Thermal Hazards
Ecology must not treat "BESS" as synonymous with legacy, first-generation lithium-ion configurations. Siting, setback, and fire suppression mitigation measures must not be applied as blanket mandates across vastly different cell chemistries.
Sodium-Ion (Na-ion): Rapidly entering utility-scale commercialization, sodium-ion cells exhibit significantly higher thermal stability, lower risk of thermal runaway, and can be transported and stored at 0 volts (zero state of charge), practically eliminating transport and construction hazard baselines.
Iron-Air and Aqueous/Flow Chemistries: Long-duration storage systems—such as iron-air and non-flammable flow batteries—operate using water-based electrolytes with virtually zero risk of fire propagation or toxic deflagration gas release.
Tiered Regulatory Pathways: The PEIS must establish tiered mitigation frameworks where inherently safe, non-propagating, or low-fire-risk chemistries qualify for expedited, minimal SEPA review rather than being forced into the heavy mitigation envelopes designed for older chemistries.
2. Mandate an "Avoided Fossil Emissions" Lifecycle Baseline
Under SEPA, the environmental impact of non-emitting grid infrastructure must be measured against real-world grid operations:
The PEIS must quantitatively model the net displaced emissions achieved by energy storage, including avoided greenhouse gases, upstream methane leakage, and localized criteria pollutants (\text{NO}_x, VOCs, and PM2.5) that occur when gas peakers dispatch during peak demand.
The PEIS must not evaluate worst-case, low-probability localized incidents (e.g., thermal runaway or fire water runoff) without directly weighting those risks against the known, continuous public health and environmental damage of fossil fuel combustion.
3. Accurately Model the Environmental Damage of the "No Action Alternative"
Treating the "No Action Alternative" as an environmentally benign baseline is factually flawed:
In the Northwest power grid, failing to deploy adequate utility-scale storage requires maintaining, running, and extending the operational lives of fossil-fueled generation to satisfy resource adequacy requirements.
The PEIS must explicitly state that the "No Action Alternative" prolongs fossil reliance, increases long-term regional carbon intensity, and directly impedes compliance with Washington's statutory decarbonization mandates.
4. Ensure the PEIS Serves as a Streamlining Mitigation Menu, Not a Moratorium Tool
Across the Pacific Northwest, open-ended environmental review processes are routinely co-opted at the municipal and county levels to justify blanket moratoria or arbitrary Special Use Permit denials under the premise of "waiting for state guidance."
The PEIS must be explicitly defined as a non-mandatory, non-exclusive mitigation menu designed to help local lead agencies rapidly complete project-level SEPA checklists.
For projects sited in appropriate areas—such as industrial zones, brownfields, or land immediately adjacent to existing electrical substations (where fossil peakers have traditionally operated)—the PEIS should provide streamlined, categorical evaluation paths.
5. Ground Hazard Assessments in Modern Design Codes (NFPA 855 / UL 9540A)
For chemistries where thermal hazards are present, safety assessments must reflect current code-compliant engineering rather than legacy failures:
Evaluations must assume compliance with modern standards including NFPA 855, UL 9540, and UL 9540A testing, which require unit-level separation, gas detection, deflagration venting, and multi-tier Battery Management Systems (BMS).
Risk modeling must account for standard utility adoption of Lithium Iron Phosphate (LFP) over older Nickel Manganese Cobalt (NMC) chemistries, reflecting LFP's higher thermal stability and resistance to self-sustaining fire.
Ecology must ensure this PEIS fulfills its mandate: accelerating the safe, timely, and rational transition to a zero-emissions grid, rather than giving incumbent fossil generation a procedural shield against clean storage competition.
Thank you for your consideration of these scoping comments.↓
No attachments
September 25, 2026
Re: Scoping comment — Stand-alone BESS Programmatic EIS (Publication 26-06-017)
To the Department of Ecology, Clean Energy Coordination:
I am writing to submit comments re the DOE's "scoping" document relating to
the Programmatic ...↓Environmental Impact Statement for stand-alone, utility-scale,
lithium-ion battery energy storage system (ie BESS) projects in Washington (Publication 26-06-017).
To WA Dept. of Ecology:
I am a third generation WA resident and voter. My family has lived on our Snoqualmie acreage in unincorporated KC for 32 years. Our family and about 50 homes in our immediate neighborhood rely on private wells for all drinking and cleaning water, and on both well and rainwater for watering crops and animals. Families in my immediate neighborhood raise chickens, goats, and sheep; eat vegetables and fruit grown in our soil, as well as eggs from hens that drink our well water. My property is immediately NEXT DOOR to the proposed Jupiter BESS plant. The issues I believe must be included in the scope of your BESS study, are the following:
1. Safety Related Issues:
a) Wind and its impact on safety in the event of fire. Our area has huge wind storms every year; one or more trees has blown down on or near our property every year over the past 32 years;
b) Impact of Terrain on likelihood of fire spread-though the trees immediately around the plant may be cut down, all of us on acreage live in the woods. Our property next door is foreest. One of my neighbors has replaced trees with grape vines and has a 5 acre vineyard. Wind will carry fire to our properties;
c) Noise and light impact on rural neighbors-Rather than merely complying with city noise and lighting ordinances, industrial plants should not be allowed to increase noise or light pollution in the rural areas next door. Light and noise pollution interferes with the quiet enjoyment of our properties;
d) Impact of BESS plants on local wildlife-here on our property, we have everything from elk and deer and cougars, to rabbits, beaver, fish, coyote, and bobcat;
e) Impact on local trees and plants;
f) Impact on soil-particularly on properties downhill (which mine is) from a proposed BESS plant;
g) Fiscal impact on neighbors-both public and private property owners, if a BESS fire or soil or water or air contamination occurs;
h) The length of time any water or soil or air contamination from a BESS fire or leak will be present, before the water, soil and air is safe for families-including children, infants, elderly, people with breathing issues and illness, and animals;
i) Impact of BESS plant staffing levels on safety: Is a tech remote monitoring system as safe as monitors on the ground 24/7 at the plant? Are remote monitors out of state (say for example in Illinois or Texas) as safe as requiring monitoring be done in Washington?
j) Impact of building surrounding batteries: Would requiring the entire plant to be enclosed in a building (rather than individual units side by side) reduce risk of pollution or fire spreading via wind?
k) Most important of all, because water is life-Potential impacts on wells and sources of drinking and cleaning water nearby. In addition to our private well, we also have a creek (which the County has identified as carrying fish, and which also carries beaver and serves as a water source for all the local wildlife) running on and parallel (west to east) to the north side of our property.
2. Mitigation related issues:
a) The potential effectiveness of long term monitoring and results reporting- by a qualified and neutral expert, of water quality and quantity-both for private wells, public water supplies, and streams and creeks, of the health of area vegetation, of noise levels, and of soil and crops grown on nearby properties;
b) Guaranteed fire prevention and suppression and response for all neighboring properties. Here in unincorporated KC, the city fire and police respond to the property within city limits, but these unincorporated properties are not protected by a fire district. Neighbors should be guaranteed protection from BESS fire.
c) Liability limits/bonds: What impact do liability limits have on corporate safety measures? If every home near a BESS plant is worth a minimum of $1 million, how does a $1 million liability limit impact the company's motivation to invest money in safety? How would the requirement to put up a liability bond for potential damage to neighbors, or even a prohibition on liability limits, compare with respect to the company's motivation to invest money in safety?
d) Drinking water supply: What actions would need to be taken, and what actions should the state require of the corporate developer if drinking water supplies are contaminated? How would that contamination be rectified? The state should at a minimum, require clean and safe drinking water to be provided to households until a replacement well can be built, or another remedy can be implemented.
e) Are people in nearby homes, schools, and parks less likely to suffer negative impacts from BESS plant(ie fire, air or water or soil pollution and breathing difficulties resulting therefrom)failures or harms, if they are further away? from the plant? What is a safe distance from a home with small children who play outside, elderly family members, or members with respiratory illnesses?
f) Does the potential danger to neighbors increase with the size of the plant? Is a 500 battery unit plant potentially more dangerous to neighbors than a 25 unit plant? Would a state limit on the maximum size of these plants increase safety for neighbors?
As this BESS issue is literally a matter of life and death, as well as physical and fiscal safety for those of us nearby who have devoted the better part of our adult lives into living, raising our families, and improving our local properties, I sincerely hope the scope of your report will include the topics of concern listed by myself and others who have submitted comment.
I look forward to reading your report.
Respectfully submitted,
Deborah Bellam↓
Re: Scoping comment — Stand-alone BESS Programmatic EIS (Publication 26-06-017)
To the Department of Ecology, Clean Energy Coordination:
I am writing to submit comments re the DOE's "scoping" document relating to
the Programmatic ...↓Environmental Impact Statement for stand-alone, utility-scale,
lithium-ion battery energy storage system (ie BESS) projects in Washington (Publication 26-06-017).
To WA Dept. of Ecology:
I am a third generation WA resident and voter. My family has lived on our Snoqualmie acreage in unincorporated KC for 32 years. Our family and about 50 homes in our immediate neighborhood rely on private wells for all drinking and cleaning water, and on both well and rainwater for watering crops and animals. Families in my immediate neighborhood raise chickens, goats, and sheep; eat vegetables and fruit grown in our soil, as well as eggs from hens that drink our well water. My property is immediately NEXT DOOR to the proposed Jupiter BESS plant. The issues I believe must be included in the scope of your BESS study, are the following:
1. Safety Related Issues:
a) Wind and its impact on safety in the event of fire. Our area has huge wind storms every year; one or more trees has blown down on or near our property every year over the past 32 years;
b) Impact of Terrain on likelihood of fire spread-though the trees immediately around the plant may be cut down, all of us on acreage live in the woods. Our property next door is foreest. One of my neighbors has replaced trees with grape vines and has a 5 acre vineyard. Wind will carry fire to our properties;
c) Noise and light impact on rural neighbors-Rather than merely complying with city noise and lighting ordinances, industrial plants should not be allowed to increase noise or light pollution in the rural areas next door. Light and noise pollution interferes with the quiet enjoyment of our properties;
d) Impact of BESS plants on local wildlife-here on our property, we have everything from elk and deer and cougars, to rabbits, beaver, fish, coyote, and bobcat;
e) Impact on local trees and plants;
f) Impact on soil-particularly on properties downhill (which mine is) from a proposed BESS plant;
g) Fiscal impact on neighbors-both public and private property owners, if a BESS fire or soil or water or air contamination occurs;
h) The length of time any water or soil or air contamination from a BESS fire or leak will be present, before the water, soil and air is safe for families-including children, infants, elderly, people with breathing issues and illness, and animals;
i) Impact of BESS plant staffing levels on safety: Is a tech remote monitoring system as safe as monitors on the ground 24/7 at the plant? Are remote monitors out of state (say for example in Illinois or Texas) as safe as requiring monitoring be done in Washington?
j) Impact of building surrounding batteries: Would requiring the entire plant to be enclosed in a building (rather than individual units side by side) reduce risk of pollution or fire spreading via wind?
k) Most important of all, because water is life-Potential impacts on wells and sources of drinking and cleaning water nearby. In addition to our private well, we also have a creek (which the County has identified as carrying fish, and which also carries beaver and serves as a water source for all the local wildlife) running on and parallel (west to east) to the north side of our property.
2. Mitigation related issues:
a) The potential effectiveness of long term monitoring and results reporting- by a qualified and neutral expert, of water quality and quantity-both for private wells, public water supplies, and streams and creeks, of the health of area vegetation, of noise levels, and of soil and crops grown on nearby properties;
b) Guaranteed fire prevention and suppression and response for all neighboring properties. Here in unincorporated KC, the city fire and police respond to the property within city limits, but these unincorporated properties are not protected by a fire district. Neighbors should be guaranteed protection from BESS fire.
c) Liability limits/bonds: What impact do liability limits have on corporate safety measures? If every home near a BESS plant is worth a minimum of $1 million, how does a $1 million liability limit impact the company's motivation to invest money in safety? How would the requirement to put up a liability bond for potential damage to neighbors, or even a prohibition on liability limits, compare with respect to the company's motivation to invest money in safety?
d) Drinking water supply: What actions would need to be taken, and what actions should the state require of the corporate developer if drinking water supplies are contaminated? How would that contamination be rectified? The state should at a minimum, require clean and safe drinking water to be provided to households until a replacement well can be built, or another remedy can be implemented.
e) Are people in nearby homes, schools, and parks less likely to suffer negative impacts from BESS plant(ie fire, air or water or soil pollution and breathing difficulties resulting therefrom)failures or harms, if they are further away? from the plant? What is a safe distance from a home with small children who play outside, elderly family members, or members with respiratory illnesses?
f) Does the potential danger to neighbors increase with the size of the plant? Is a 500 battery unit plant potentially more dangerous to neighbors than a 25 unit plant? Would a state limit on the maximum size of these plants increase safety for neighbors?
As this BESS issue is literally a matter of life and death, as well as physical and fiscal safety for those of us nearby who have devoted the better part of our adult lives into living, raising our families, and improving our local properties, I sincerely hope the scope of your report will include the topics of concern listed by myself and others who have submitted comment.
I look forward to reading your report.
Respectfully submitted,
Deborah Bellam↓
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I believe that Battery Energy Storage Systems are a critical part of improving grid resiliency as more solar and wind are added and as we move away from natural gas plants. I'm advocating for thoughtful regulations that enable them to move forward wi...↓thout putting anyone near the sites in any increased danger.
Designs should take into account the possibility of thermal runaway and how best to prevent or mitigate it, and local response crews should be trained in how to deal with any incidents.
While Lithium Ion is the most current common battery type I think it is worth the effort and cost to explore alternatives like Sodium Ion which may prove to be inherently safer and provide flexibility to how the regulations may cover BESS.
I also think some amount of regulation should be required around how the batteries will be managed at end-of-life that require the operator to properly recycle or dispose of what's left with adequate funding provided for at the outset.
Thank you↓
Designs should take into account the possibility of thermal runaway and how best to prevent or mitigate it, and local response crews should be trained in how to deal with any incidents.
While Lithium Ion is the most current common battery type I think it is worth the effort and cost to explore alternatives like Sodium Ion which may prove to be inherently safer and provide flexibility to how the regulations may cover BESS.
I also think some amount of regulation should be required around how the batteries will be managed at end-of-life that require the operator to properly recycle or dispose of what's left with adequate funding provided for at the outset.
Thank you↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is James Hietala and I live at 35328 SE Kinsey St, Snoqualmie WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-s...↓cale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Cascadia Ridge project. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
James Hietala
35328 SE Kinsey St, Snoqualmie WA↓
My name is James Hietala and I live at 35328 SE Kinsey St, Snoqualmie WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-s...↓cale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Cascadia Ridge project. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
James Hietala
35328 SE Kinsey St, Snoqualmie WA↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Cecilia Novak and I live at 8830 Satterlee Ave SE, Snoqualmie, WA, 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-...↓alone, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Snoqualmie Ridge has a population of over 13,500 residents. Locally, there are over 40 parks and more than 30 miles of trails. Near these parks and trails are critical wetlands, native plants, and protected animals.
Q3 · Impacts to analyze — The harms the study must consider.
Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
King County Fire Protection District 38 has formally sent a letter to the WUTC that they do not have the proper resources to handle a BESS emergency. The local, small hospital, Snoqualmie Valley Health, has a Level 5 Trauma designation. Handling only minor to moderate injuries mean that they do not have the capability to care for more serious injuries. The Snoqualmie Valley School district also requests an environmental review to mitigate impacts to its students and staff. This is important to note since those under 18 years of age make up more than 33% of the population.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My household depends on Snoqualmie Parkway, which is also an emergency route for Snoqualmie Ridge.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Cecilia Novak
8830 Satterlee Ave SE, Snoqualmie, WA, 98065↓
My name is Cecilia Novak and I live at 8830 Satterlee Ave SE, Snoqualmie, WA, 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-...↓alone, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Snoqualmie Ridge has a population of over 13,500 residents. Locally, there are over 40 parks and more than 30 miles of trails. Near these parks and trails are critical wetlands, native plants, and protected animals.
Q3 · Impacts to analyze — The harms the study must consider.
Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
King County Fire Protection District 38 has formally sent a letter to the WUTC that they do not have the proper resources to handle a BESS emergency. The local, small hospital, Snoqualmie Valley Health, has a Level 5 Trauma designation. Handling only minor to moderate injuries mean that they do not have the capability to care for more serious injuries. The Snoqualmie Valley School district also requests an environmental review to mitigate impacts to its students and staff. This is important to note since those under 18 years of age make up more than 33% of the population.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My household depends on Snoqualmie Parkway, which is also an emergency route for Snoqualmie Ridge.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Cecilia Novak
8830 Satterlee Ave SE, Snoqualmie, WA, 98065↓
No attachments
Dear Policymakers:
I write to provide public comment in response to the Scoping Meeting for Battery Energy Storage Systems and the associated Programmatic EIS. I write to raise concerns over the proposed and existing siting standards for Battery Ener...↓gy Storage Systems (BESS) and microgrids and the State's environmental noise standards governing school sites under WAC 246-366-030. While I support clean-energy goals, I believe the current 100-foot minimum separation standard for siting BESS near sensitive uses — including schools — was developed primarily to address fire and life-safety hazards, and has not been independently evaluated against the acoustic thresholds that school sites are separately required to meet. This gap creates real risk of unfunded mitigation burdens for school districts and, ultimately, local taxpayers.
1. Regulatory Background
1.1 State Noise Standard for School Sites
WAC 246-366-030(3) provides that noise from any source at a proposed site for a new school, an addition to an existing school, or a portable classroom shall not exceed an hourly average of 55 dBA (Leq, 60 minutes) and shall not exceed an hourly maximum (Lmax) of 75 dBA during the time of day the school is in session. Sites that exceed these levels remain permissible only if a sound-reduction plan is included in the construction proposal and approved by the local health officer. This standard was confirmed as currently applicable in a November 2025 presentation by the Tacoma-Pierce County Health Department, which continues to apply this citation in its review of school site approvals.
1.2 Pierce County BESS Siting Standard
One example of a local jurisdiction's siting distances is Pierce County's current BESS regulatory framework, which designates any location within 100 feet of sensitive uses — including schools, childcare facilities, and medical facilities — as an area excluded from consideration for BESS siting through the conditional use permit process. A BESS or microgrid facility may be sited as close as 100 feet from a school property line. The County has described the purpose of this exclusion as prioritizing public safety by reducing potential exposure to hazards and ensuring appropriate separation from vulnerable populations. Notably, this rationale is framed entirely around fire and hazard safety; it does not reference or appear to account for the acoustic thresholds school sites must independently satisfy under WAC 246-366-030.
2. Noise Propagation Analysis
Manufacturer and industry data indicate that BESS enclosures produce average sound levels ranging from approximately 70 to 92 dBA at a distance of 1 meter (3 feet), driven primarily by continuous cooling-fan operation. Using standard point-source spherical-spreading attenuation (20·log10(d2/d1) — equivalent to roughly 6 dB reduction per doubling of distance), it's estimated sound levels at increasing distances from the enclosure under idealized free-field conditions (hard ground, no barriers, no atmospheric absorption, single unit only). This method represents a best-case propagation scenario; real-world levels could be higher where multiple units operate simultaneously or where reflective surfaces are present, or lower where soft ground, vegetation, or terrain provide additional attenuation.
Distance from enclosure Low estimate (70 dBA @ 1m) High estimate (92 dBA @ 1m)
1 m (3 ft) 70 dBA 92 dBA
3 m (10 ft) 60.5 dBA 82.5 dBA
10 m (33 ft) 50.0 dBA 72.0 dBA
30 m (100 ft) — Pierce Co. minimum setback 40.3 dBA 62.3 dBA
61 m (200 ft) 34.3 dBA 56.3 dBA
91 m (300 ft) 30.8 dBA 52.8 dBA
152 m (500 ft) 26.3 dBA 48.3 dBA
Figure 1. Estimated BESS sound level vs. distance under idealized free-field spherical spreading, relative to the WAC 246-366-030 Leq/Lmax thresholds and the County's 100-foot minimum setback.
This analysis indicates that at this County's 100-foot minimum setback, equipment operating at the upper end of the stated emission range (92 dBA at 1 meter) would be expected to generate approximately 62 dBA at the property line — roughly 7 dBA above the 55 dBA hourly Leq threshold required at school sites under WAC 246-366-030(3). Solving the same relationship in reverse, compliance with the 55 dBA Leq threshold is not reached until approximately 230 feet from a source at the top of the stated range — more than double the County's current minimum setback.
In practical terms, this means this example County's current setback may be substantially insufficient for higher-emission installations, and does not provide school districts or the health officer reviewing school site applications with confidence that a nearby BESS facility will not push a school site out of noise compliance.
3. Cost-Shifting Concerns
I am also concerned about where the financial burden of noise mitigation falls under the current framework. As a matter of general practice, the cost of mitigating an environmental impact is typically borne by the party that creates it. Highway noise walls are funded as part of the roadway project that generates the excess noise, not by adjacent property owners. Industrial and utility siting permits routinely condition approval on the applicant funding acoustic enclosures, buffers, or setbacks. Environmental review under SEPA generally requires mitigation to be funded by the project proponent, not by third parties.
School districts already bear this obligation for noise originating from conditions outside their control — WAC 246-366-030(3) requires the district applying for site approval to fund the noise study and any needed mitigation for its own proposed site. That allocation is reasonable when the district is choosing where to build near pre-existing conditions. It is a different matter when a new, avoidable industrial noise source is permitted after a school already exists, or after a district has an adopted capital facilities plan identifying a future site, at a distance the County itself controls and allows. In that scenario, the district — and ultimately local taxpayers, through capital levies and bond funds — bears the cost of a problem it did not create and had no opportunity to prevent through site selection.
I recommend policy makers consider the following to better align responsibility with cause:
● Require BESS/microgrid developers to submit a pre-siting acoustic analysis showing expected sound levels at the nearest existing or planned school property line as part of the conditional use permit application.
● Where a proposed BESS site would foreseeably push a nearby school site out of compliance with WAC 246-366-030, require the developer — not the school district — to fund necessary mitigation (acoustic enclosures, barriers, or an increased setback).
● Alternatively, increase the presumptive minimum setback between BESS facilities and school properties (existing or planned) to a distance informed by the full stated emission range of this equipment, so that noise-driven mitigation is rarely triggered in the first place.
4. Conclusion
A 100-foot BESS setback appears to have been calibrated to address fire and hazard safety, not acoustic compliance, and my analysis suggests it may leave a meaningful gap between what the County allows and what state law requires at school sites. I ask policymakers to evaluate the acoustic adequacy of the current setback standard, particularly for higher-emission BESS installations, and to consider mechanisms that place the cost of any needed noise mitigation on the party introducing the noise source rather than on school districts and local taxpayers. I appreciate the DOE's attention to this issue and welcome the opportunity to discuss these concerns further.
Respectfully submitted,
Caitlin McIntyre
Sources
● WAC 246-366-030 — Site Approval (Washington State Board of Health).
● Tacoma-Pierce County Health Department, "Noise From a Local Health Jurisdiction Perspective," School Workshop presentation, November 6, 2025.
● Washington State Board of Health, Rules Hearing Cover Memo — Repeal of Chapter 246-366A WAC, June 4, 2025.
● Pierce County Planning & Public Works, "Solar in County Code" / BESS exclusion area map and Solar Energy & BESS presentation, March 24, 2026.
● Noise-propagation estimates calculated by the authors using standard point-source spherical-spreading attenuation (20·log10(d2/d1)) from manufacturer-reported BESS enclosure sound levels of 70–92 dBA at 1 meter.
Attached is a local news station's report that demonstrates how loud these mini grids can sound to the adjacent neighbors.↓
I write to provide public comment in response to the Scoping Meeting for Battery Energy Storage Systems and the associated Programmatic EIS. I write to raise concerns over the proposed and existing siting standards for Battery Ener...↓gy Storage Systems (BESS) and microgrids and the State's environmental noise standards governing school sites under WAC 246-366-030. While I support clean-energy goals, I believe the current 100-foot minimum separation standard for siting BESS near sensitive uses — including schools — was developed primarily to address fire and life-safety hazards, and has not been independently evaluated against the acoustic thresholds that school sites are separately required to meet. This gap creates real risk of unfunded mitigation burdens for school districts and, ultimately, local taxpayers.
1. Regulatory Background
1.1 State Noise Standard for School Sites
WAC 246-366-030(3) provides that noise from any source at a proposed site for a new school, an addition to an existing school, or a portable classroom shall not exceed an hourly average of 55 dBA (Leq, 60 minutes) and shall not exceed an hourly maximum (Lmax) of 75 dBA during the time of day the school is in session. Sites that exceed these levels remain permissible only if a sound-reduction plan is included in the construction proposal and approved by the local health officer. This standard was confirmed as currently applicable in a November 2025 presentation by the Tacoma-Pierce County Health Department, which continues to apply this citation in its review of school site approvals.
1.2 Pierce County BESS Siting Standard
One example of a local jurisdiction's siting distances is Pierce County's current BESS regulatory framework, which designates any location within 100 feet of sensitive uses — including schools, childcare facilities, and medical facilities — as an area excluded from consideration for BESS siting through the conditional use permit process. A BESS or microgrid facility may be sited as close as 100 feet from a school property line. The County has described the purpose of this exclusion as prioritizing public safety by reducing potential exposure to hazards and ensuring appropriate separation from vulnerable populations. Notably, this rationale is framed entirely around fire and hazard safety; it does not reference or appear to account for the acoustic thresholds school sites must independently satisfy under WAC 246-366-030.
2. Noise Propagation Analysis
Manufacturer and industry data indicate that BESS enclosures produce average sound levels ranging from approximately 70 to 92 dBA at a distance of 1 meter (3 feet), driven primarily by continuous cooling-fan operation. Using standard point-source spherical-spreading attenuation (20·log10(d2/d1) — equivalent to roughly 6 dB reduction per doubling of distance), it's estimated sound levels at increasing distances from the enclosure under idealized free-field conditions (hard ground, no barriers, no atmospheric absorption, single unit only). This method represents a best-case propagation scenario; real-world levels could be higher where multiple units operate simultaneously or where reflective surfaces are present, or lower where soft ground, vegetation, or terrain provide additional attenuation.
Distance from enclosure Low estimate (70 dBA @ 1m) High estimate (92 dBA @ 1m)
1 m (3 ft) 70 dBA 92 dBA
3 m (10 ft) 60.5 dBA 82.5 dBA
10 m (33 ft) 50.0 dBA 72.0 dBA
30 m (100 ft) — Pierce Co. minimum setback 40.3 dBA 62.3 dBA
61 m (200 ft) 34.3 dBA 56.3 dBA
91 m (300 ft) 30.8 dBA 52.8 dBA
152 m (500 ft) 26.3 dBA 48.3 dBA
Figure 1. Estimated BESS sound level vs. distance under idealized free-field spherical spreading, relative to the WAC 246-366-030 Leq/Lmax thresholds and the County's 100-foot minimum setback.
This analysis indicates that at this County's 100-foot minimum setback, equipment operating at the upper end of the stated emission range (92 dBA at 1 meter) would be expected to generate approximately 62 dBA at the property line — roughly 7 dBA above the 55 dBA hourly Leq threshold required at school sites under WAC 246-366-030(3). Solving the same relationship in reverse, compliance with the 55 dBA Leq threshold is not reached until approximately 230 feet from a source at the top of the stated range — more than double the County's current minimum setback.
In practical terms, this means this example County's current setback may be substantially insufficient for higher-emission installations, and does not provide school districts or the health officer reviewing school site applications with confidence that a nearby BESS facility will not push a school site out of noise compliance.
3. Cost-Shifting Concerns
I am also concerned about where the financial burden of noise mitigation falls under the current framework. As a matter of general practice, the cost of mitigating an environmental impact is typically borne by the party that creates it. Highway noise walls are funded as part of the roadway project that generates the excess noise, not by adjacent property owners. Industrial and utility siting permits routinely condition approval on the applicant funding acoustic enclosures, buffers, or setbacks. Environmental review under SEPA generally requires mitigation to be funded by the project proponent, not by third parties.
School districts already bear this obligation for noise originating from conditions outside their control — WAC 246-366-030(3) requires the district applying for site approval to fund the noise study and any needed mitigation for its own proposed site. That allocation is reasonable when the district is choosing where to build near pre-existing conditions. It is a different matter when a new, avoidable industrial noise source is permitted after a school already exists, or after a district has an adopted capital facilities plan identifying a future site, at a distance the County itself controls and allows. In that scenario, the district — and ultimately local taxpayers, through capital levies and bond funds — bears the cost of a problem it did not create and had no opportunity to prevent through site selection.
I recommend policy makers consider the following to better align responsibility with cause:
● Require BESS/microgrid developers to submit a pre-siting acoustic analysis showing expected sound levels at the nearest existing or planned school property line as part of the conditional use permit application.
● Where a proposed BESS site would foreseeably push a nearby school site out of compliance with WAC 246-366-030, require the developer — not the school district — to fund necessary mitigation (acoustic enclosures, barriers, or an increased setback).
● Alternatively, increase the presumptive minimum setback between BESS facilities and school properties (existing or planned) to a distance informed by the full stated emission range of this equipment, so that noise-driven mitigation is rarely triggered in the first place.
4. Conclusion
A 100-foot BESS setback appears to have been calibrated to address fire and hazard safety, not acoustic compliance, and my analysis suggests it may leave a meaningful gap between what the County allows and what state law requires at school sites. I ask policymakers to evaluate the acoustic adequacy of the current setback standard, particularly for higher-emission BESS installations, and to consider mechanisms that place the cost of any needed noise mitigation on the party introducing the noise source rather than on school districts and local taxpayers. I appreciate the DOE's attention to this issue and welcome the opportunity to discuss these concerns further.
Respectfully submitted,
Caitlin McIntyre
Sources
● WAC 246-366-030 — Site Approval (Washington State Board of Health).
● Tacoma-Pierce County Health Department, "Noise From a Local Health Jurisdiction Perspective," School Workshop presentation, November 6, 2025.
● Washington State Board of Health, Rules Hearing Cover Memo — Repeal of Chapter 246-366A WAC, June 4, 2025.
● Pierce County Planning & Public Works, "Solar in County Code" / BESS exclusion area map and Solar Energy & BESS presentation, March 24, 2026.
● Noise-propagation estimates calculated by the authors using standard point-source spherical-spreading attenuation (20·log10(d2/d1)) from manufacturer-reported BESS enclosure sound levels of 70–92 dBA at 1 meter.
Attached is a local news station's report that demonstrates how loud these mini grids can sound to the adjacent neighbors.↓
Attachments:
Thank you for your information session this afternoon. Our scoping input about BESS facilities relate to water resources, specifically focused on BESS siting in relation to drinking water sources:
• Location within the sanitary control area (100' rad...↓ius) associated with any drinking water well, public or private (WAC 173-160-101 & -171; 246-290-135(2)); & 246-291-125(5)); and
• Location within the larger wellhead protection areas associated with public drinking water systems (WAC 246-290-135(3)(c)(ii) & 246-291-125(3)(d)(ii)).
In 2024, we commented on SEPA review associated with a city development permit for a BESS facility. We are providing this excerpt adapted from those comments we feel would illuminate broader PEIS scoping, including the reference documents we offered to the city at that time (note: live links did not work here so we've substituted URLs below):
The chief drinking water concern associated with BESS facilities isn't so much in their everyday operation, but in case of emergency. A battery system poses certain inherent fire hazards associated with the possibility of thermal runaway. Our focused concern is the possibility of chemical contamination in case of emergency, where chemical releases can commingle with firefighting water to contaminate soil and/or ground water, either directly or as runoff. If a public drinking water source is compromised in such a manner by a BESS facility, the water purveyor could potentially lose its investment in the well and need to shut it down, either temporarily or permanently as dictated by the situation. Further, if the source water (aquifer) itself is impacted, it could affect a greater number of drinking water systems and private wells than a single proximate source.
We're sharing a number of related resources below. We encourage you to take a critical look at these materials, and any others to this point that you may locate, to identify measures beyond everyday best practices to deal with emergency situations that may occur in relation to BESS facilities.
Of particular note, the Travelers article states that in case of fire, improper firefighting techniques can make things worse and potentially result in additional harm. It goes on to say that emergency response must be tailored to that specific BESS operation. Further, the Water Research Foundation report offers a number of recommendations around fire hazard control in situ and says that besides fire potential, consideration should be given to hazardous materials transportation and handling both on- and off-site: "Preventative mitigation measures required to prevent any substantial hazards to the public or environment through the routine transport, use, or disposal of hazardous materials should be considered for BESS projects."
https://www.waterrf.org/research/projects/battery-storage-system-guidance-water-and-wastewater-utilities
https://www.travelers.com/resources/business-industries/energy/lithium-ion-battery-energy-storage-emerging-risks-business
https://www.sciencedirect.com/science/article/abs/pii/S1364032119300334
https://www.bakerrisk.com/news/myths-battery-energy-storage-systems/
https://www.exponent.com/case-studies/firefighting-water-battery-fires-hazardous
https://www.labellapc.com/insights/bess-thermal-events-what-to-know-and-what-to-expect/
-end of excerpt-
Specific to the 2024 permit, we encouraged the city involved to, at minimum, require a hydrogeo report demonstrating the site's relationship with groundwater providing drinking water to the specific drinking water source of concern. We recommended they (a) involve their drinking water utility staff in this aspect of permit review; and (b) apply mitigation measures up to and including replacement of the water source if it appeared that an emergency situation at the site would pose contamination potential to the public drinking water or any other drinking water source. These type of recommended responses may be generally replicable in a PEIS.
Thank you for your consideration.↓
• Location within the sanitary control area (100' rad...↓ius) associated with any drinking water well, public or private (WAC 173-160-101 & -171; 246-290-135(2)); & 246-291-125(5)); and
• Location within the larger wellhead protection areas associated with public drinking water systems (WAC 246-290-135(3)(c)(ii) & 246-291-125(3)(d)(ii)).
In 2024, we commented on SEPA review associated with a city development permit for a BESS facility. We are providing this excerpt adapted from those comments we feel would illuminate broader PEIS scoping, including the reference documents we offered to the city at that time (note: live links did not work here so we've substituted URLs below):
The chief drinking water concern associated with BESS facilities isn't so much in their everyday operation, but in case of emergency. A battery system poses certain inherent fire hazards associated with the possibility of thermal runaway. Our focused concern is the possibility of chemical contamination in case of emergency, where chemical releases can commingle with firefighting water to contaminate soil and/or ground water, either directly or as runoff. If a public drinking water source is compromised in such a manner by a BESS facility, the water purveyor could potentially lose its investment in the well and need to shut it down, either temporarily or permanently as dictated by the situation. Further, if the source water (aquifer) itself is impacted, it could affect a greater number of drinking water systems and private wells than a single proximate source.
We're sharing a number of related resources below. We encourage you to take a critical look at these materials, and any others to this point that you may locate, to identify measures beyond everyday best practices to deal with emergency situations that may occur in relation to BESS facilities.
Of particular note, the Travelers article states that in case of fire, improper firefighting techniques can make things worse and potentially result in additional harm. It goes on to say that emergency response must be tailored to that specific BESS operation. Further, the Water Research Foundation report offers a number of recommendations around fire hazard control in situ and says that besides fire potential, consideration should be given to hazardous materials transportation and handling both on- and off-site: "Preventative mitigation measures required to prevent any substantial hazards to the public or environment through the routine transport, use, or disposal of hazardous materials should be considered for BESS projects."
https://www.waterrf.org/research/projects/battery-storage-system-guidance-water-and-wastewater-utilities
https://www.travelers.com/resources/business-industries/energy/lithium-ion-battery-energy-storage-emerging-risks-business
https://www.sciencedirect.com/science/article/abs/pii/S1364032119300334
https://www.bakerrisk.com/news/myths-battery-energy-storage-systems/
https://www.exponent.com/case-studies/firefighting-water-battery-fires-hazardous
https://www.labellapc.com/insights/bess-thermal-events-what-to-know-and-what-to-expect/
-end of excerpt-
Specific to the 2024 permit, we encouraged the city involved to, at minimum, require a hydrogeo report demonstrating the site's relationship with groundwater providing drinking water to the specific drinking water source of concern. We recommended they (a) involve their drinking water utility staff in this aspect of permit review; and (b) apply mitigation measures up to and including replacement of the water source if it appeared that an emergency situation at the site would pose contamination potential to the public drinking water or any other drinking water source. These type of recommended responses may be generally replicable in a PEIS.
Thank you for your consideration.↓
No attachments
Scoping comment — Stand-alone BESS Programmatic EIS (Publication 26-06-017)
To the Department of Ecology, Clean Energy Coordination:
My name is Nicole Wolfley and I live at 36529 Forest St SE. I am writing to submit a scoping comment on the Programm...↓atic Environmental Impact Statement for stand-alone, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I would like the study to name specific, measurable protections a permit can require. Protections described "at a high level" give my county nothing to write into a permit. The study should be specific enough to give local reviewers something to hold a developer to, because my county will lean on it when it reviews a real project. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My children attend school near a proposed stand-alone BESS site, at Snoqualmie Elementary.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Nicole Wolfley
36529 Forest St SE↓
To the Department of Ecology, Clean Energy Coordination:
My name is Nicole Wolfley and I live at 36529 Forest St SE. I am writing to submit a scoping comment on the Programm...↓atic Environmental Impact Statement for stand-alone, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I would like the study to name specific, measurable protections a permit can require. Protections described "at a high level" give my county nothing to write into a permit. The study should be specific enough to give local reviewers something to hold a developer to, because my county will lean on it when it reviews a real project. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My children attend school near a proposed stand-alone BESS site, at Snoqualmie Elementary.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Nicole Wolfley
36529 Forest St SE↓
No attachments
City of Covingtong uploaded a memo dated Sept 22, 2026 with comments for Ecology to consider in the BESS PEIS scoping process.
Attachments:
To the Department of Ecology, Clean Energy Coordination:
My name is Susan VerGowe and I live at 7830 Cortland Ave SE, Snoqualmie. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-sc...↓ale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The Snoqualmie Valley has VERY limited evacuation routes that rapidly clog to as standstill. Efficient quick and reliable evacuation routes must exist for all people within a 3-5 mile radius of any Battery Storage Facility. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live under 1 mile from the proposed site. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Susan VerGowe
7830 Cortland Ave SE, Snoqualmie↓
My name is Susan VerGowe and I live at 7830 Cortland Ave SE, Snoqualmie. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-sc...↓ale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The Snoqualmie Valley has VERY limited evacuation routes that rapidly clog to as standstill. Efficient quick and reliable evacuation routes must exist for all people within a 3-5 mile radius of any Battery Storage Facility. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live under 1 mile from the proposed site. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Susan VerGowe
7830 Cortland Ave SE, Snoqualmie↓
No attachments
Subject: Scoping comments on the Battery Energy Storage Systems PEIS, Publication 26-06-017
Dear Ecology Clean Energy Coordination Team:
I am submitting these comments as an individual resident of Sedro-Woolley, Washington. I generally support batt...↓ery energy storage with appropriate safeguards. I want this study to help communities make informed decisions about where facilities belong, how people will be protected, and who will remain responsible throughout a facility's life.
I appreciate Ecology's inclusion of environmental health and safety, land use, water resources, public services, and cumulative impacts. My requests concern the practical detail needed to make that analysis useful, particularly for smaller communities. I understand that this statewide study will inform subsequent project reviews and does not decide individual permits. [1]
Siting and compatibility
For Sections 5.2 and 5.3, please explain how the study will compare facility types and identify suitable geographic areas. Proximity to electrical infrastructure should be considered alongside environmental constraints and the ability to protect nearby people.
Evaluate how siting considerations change with power output, total stored energy, battery chemistry, enclosure design, and protective systems. Please identify which differences materially affect potential impacts and what information local reviewers need to evaluate them.
Develop screening guidance addressing nearby homes, schools, care facilities, waterways, flood and seismic hazards, emergency access, and evacuation routes. Include routine operating noise and cumulative demands where multiple facilities depend on the same response resources. Explain how disproportionate impacts and tribal rights and resources will inform the analysis.
The useful result would be evidence-based criteria for identifying lower-conflict locations and conditions requiring closer review. Where separation distances are discussed, explain their purpose, supporting evidence, and limits. Distinguish equipment spacing from protection of neighboring uses and incident-specific emergency zones.
Public notification and understandable information
Within Section 5.4 and any companion guidance, please evaluate how early public information can improve siting decisions and implementation of safeguards.
Residents should have an opportunity to understand a proposal while meaningful choices remain available. Please identify the information needed at that stage, including facility scale, technology, potential impacts, proposed safeguards, responsible contacts, and opportunities to comment. Evaluate notification that reaches renters, nearby residents across jurisdictional boundaries, and people who need translated or accessible information.
Separately, examine emergency alerts: who issues them, how agencies coordinate, and how people without reliable internet access receive instructions. Include residents who may need assistance evacuating and facilities responsible for people in their care.
Please recommend a public-information checklist and criteria for renewed notice when changes materially affect impacts or response plans. Distinguish required disclosures from recommended practices, and identify legitimate security limits without unnecessarily withholding useful safety information.
Fire response and local preparedness
For Section 4 and Section 5.4, please evaluate credible incident scenarios and the capabilities needed to manage them. EPA's guidance supports advance coordination with responders and consideration of emissions, runoff, and damaged-battery handling. [2]
The study should distinguish relevant battery chemistries and configurations when drawing lessons from incidents. Explain limitations in incident data and identify remaining uncertainty, including the possibility of extended incidents or re-ignition.
Please develop a method for assessing readiness before operation. It should address detection and notification, site access, trained personnel, equipment, operator support, mutual aid, and continued emergency coverage elsewhere in the community. Include how training and plans remain current through staffing, ownership, or equipment changes.
Evaluate air monitoring, public protective actions, and water supply and runoff containment where relevant to the response strategy. Identify what would trigger post-incident sampling and how results would be communicated.
Please explain what equipment certification and representative fire testing establish and what still requires evaluation for the actual installation. UL 9540A is a test method; local reviewers need help understanding the applicability and limitations of test results. [3] Clearly separate enforceable Washington requirements from newer standards or recommended practices. Response guidance should account for the installation and incident rather than prescribe one tactic for every facility.
Decommissioning and site restoration
Please make end-of-life responsibilities explicit in Section 5.4. Evaluate normal retirement alongside early closure, abandonment, ownership changes, repowering, and incident-damaged facilities.
Identify the components of a credible plan: responsible parties, implementation triggers, schedules, removal and transport arrangements, waste destinations, contamination assessment, restoration, and verification that work is complete.
The analysis should address whether suitable contractors and disposal or recycling capacity would be available when needed, particularly for damaged batteries. Explain what happens if the original operator is no longer available or an intended recycling arrangement falls through.
NYSERDA's advisory model offers examples of decommissioning and ownership-transfer provisions for comparison, although it does not establish Washington requirements. [4] Please evaluate which approaches could usefully inform Washington guidance.
Financial responsibility and implementation
Please evaluate how the safeguards identified in the study would remain funded when they are needed. A plan should identify both the responsible party and a reliable means of carrying out the work.
Compare the purposes and limitations of insurance, decommissioning security, contractual commitments, and cost-recovery arrangements. Consider independently reviewed cost estimates, inflation, changes in facility design, uncertain salvage value, insolvency, coverage exclusions, and access to funds following an incident.
Distinguish routine retirement costs from incident cleanup and ongoing preparedness. Examine whether obligations and financial protection remain effective through ownership transfers and how deficiencies would be identified and corrected.
For each approach, identify the responsible agency, available authority, and any need for additional policy or legislation. Washington's SEPA rule ties applicant mitigation obligations to identified project impacts and requires consideration of existing requirements. [5] Recommendations should respect those limits while addressing gaps that could leave necessary work unfinished or costs with the public.
I would find a concise local-government checklist especially useful: what must be evaluated, what evidence is needed, who implements each safeguard, and how completion is verified. Please distinguish existing requirements, recommended practices, and questions reserved for individual project review. Where an issue falls outside this PEIS, identify a practical route for companion guidance or interagency work.
Thank you for considering these requests. My goal is responsible battery storage development supported by clear expectations that communities, responders, and project owners can put into practice.
Karl de Jong
Sedro-Woolley, Washington
References
[1] Washington Department of Ecology. Battery Energy Storage Systems PEIS Scoping Document, Publication 26-06-017, September 2026. Sections 1.3–1.4, pp. 11–12; Section 4, pp. 16–19; Sections 5.2–5.4, pp. 20–22.
https://apps.ecology.wa.gov/publications/documents/2606017.pdf
[2] U.S. Environmental Protection Agency. Battery Energy Storage Systems: Main Considerations for Safe Installation and Incident Response, EPA 530-F-25-013, July 2025, pp. 1–3.
https://www.epa.gov/system/files/documents/2025-08/battery_energy_storage_systems_fact_sheet.pdf
[3] UL Solutions. Installation Codes and Requirements for Energy Storage Systems (ESS) – FAQs. Accessed September 22, 2026.
https://www.ul.com/resources/installation-codes-and-requirements-energy-storage-systems-ess-faqs
[4] NYSERDA. New York Battery Energy Storage System Guidebook for Local Governments, November 2024. Advisory status, p. 1; model-law provisions, printed pp. 10–13.
https://www.nyserda.ny.gov/-/media/Project/Nyserda/files/Programs/clean-energy-siting/battery-storage-guidebook.pdf
[5] Washington Administrative Code, WAC 197-11-660, particularly subsection (1)(a)–(e).
https://app.leg.wa.gov/WAC/default.aspx?cite=197-11-660↓
Dear Ecology Clean Energy Coordination Team:
I am submitting these comments as an individual resident of Sedro-Woolley, Washington. I generally support batt...↓ery energy storage with appropriate safeguards. I want this study to help communities make informed decisions about where facilities belong, how people will be protected, and who will remain responsible throughout a facility's life.
I appreciate Ecology's inclusion of environmental health and safety, land use, water resources, public services, and cumulative impacts. My requests concern the practical detail needed to make that analysis useful, particularly for smaller communities. I understand that this statewide study will inform subsequent project reviews and does not decide individual permits. [1]
Siting and compatibility
For Sections 5.2 and 5.3, please explain how the study will compare facility types and identify suitable geographic areas. Proximity to electrical infrastructure should be considered alongside environmental constraints and the ability to protect nearby people.
Evaluate how siting considerations change with power output, total stored energy, battery chemistry, enclosure design, and protective systems. Please identify which differences materially affect potential impacts and what information local reviewers need to evaluate them.
Develop screening guidance addressing nearby homes, schools, care facilities, waterways, flood and seismic hazards, emergency access, and evacuation routes. Include routine operating noise and cumulative demands where multiple facilities depend on the same response resources. Explain how disproportionate impacts and tribal rights and resources will inform the analysis.
The useful result would be evidence-based criteria for identifying lower-conflict locations and conditions requiring closer review. Where separation distances are discussed, explain their purpose, supporting evidence, and limits. Distinguish equipment spacing from protection of neighboring uses and incident-specific emergency zones.
Public notification and understandable information
Within Section 5.4 and any companion guidance, please evaluate how early public information can improve siting decisions and implementation of safeguards.
Residents should have an opportunity to understand a proposal while meaningful choices remain available. Please identify the information needed at that stage, including facility scale, technology, potential impacts, proposed safeguards, responsible contacts, and opportunities to comment. Evaluate notification that reaches renters, nearby residents across jurisdictional boundaries, and people who need translated or accessible information.
Separately, examine emergency alerts: who issues them, how agencies coordinate, and how people without reliable internet access receive instructions. Include residents who may need assistance evacuating and facilities responsible for people in their care.
Please recommend a public-information checklist and criteria for renewed notice when changes materially affect impacts or response plans. Distinguish required disclosures from recommended practices, and identify legitimate security limits without unnecessarily withholding useful safety information.
Fire response and local preparedness
For Section 4 and Section 5.4, please evaluate credible incident scenarios and the capabilities needed to manage them. EPA's guidance supports advance coordination with responders and consideration of emissions, runoff, and damaged-battery handling. [2]
The study should distinguish relevant battery chemistries and configurations when drawing lessons from incidents. Explain limitations in incident data and identify remaining uncertainty, including the possibility of extended incidents or re-ignition.
Please develop a method for assessing readiness before operation. It should address detection and notification, site access, trained personnel, equipment, operator support, mutual aid, and continued emergency coverage elsewhere in the community. Include how training and plans remain current through staffing, ownership, or equipment changes.
Evaluate air monitoring, public protective actions, and water supply and runoff containment where relevant to the response strategy. Identify what would trigger post-incident sampling and how results would be communicated.
Please explain what equipment certification and representative fire testing establish and what still requires evaluation for the actual installation. UL 9540A is a test method; local reviewers need help understanding the applicability and limitations of test results. [3] Clearly separate enforceable Washington requirements from newer standards or recommended practices. Response guidance should account for the installation and incident rather than prescribe one tactic for every facility.
Decommissioning and site restoration
Please make end-of-life responsibilities explicit in Section 5.4. Evaluate normal retirement alongside early closure, abandonment, ownership changes, repowering, and incident-damaged facilities.
Identify the components of a credible plan: responsible parties, implementation triggers, schedules, removal and transport arrangements, waste destinations, contamination assessment, restoration, and verification that work is complete.
The analysis should address whether suitable contractors and disposal or recycling capacity would be available when needed, particularly for damaged batteries. Explain what happens if the original operator is no longer available or an intended recycling arrangement falls through.
NYSERDA's advisory model offers examples of decommissioning and ownership-transfer provisions for comparison, although it does not establish Washington requirements. [4] Please evaluate which approaches could usefully inform Washington guidance.
Financial responsibility and implementation
Please evaluate how the safeguards identified in the study would remain funded when they are needed. A plan should identify both the responsible party and a reliable means of carrying out the work.
Compare the purposes and limitations of insurance, decommissioning security, contractual commitments, and cost-recovery arrangements. Consider independently reviewed cost estimates, inflation, changes in facility design, uncertain salvage value, insolvency, coverage exclusions, and access to funds following an incident.
Distinguish routine retirement costs from incident cleanup and ongoing preparedness. Examine whether obligations and financial protection remain effective through ownership transfers and how deficiencies would be identified and corrected.
For each approach, identify the responsible agency, available authority, and any need for additional policy or legislation. Washington's SEPA rule ties applicant mitigation obligations to identified project impacts and requires consideration of existing requirements. [5] Recommendations should respect those limits while addressing gaps that could leave necessary work unfinished or costs with the public.
I would find a concise local-government checklist especially useful: what must be evaluated, what evidence is needed, who implements each safeguard, and how completion is verified. Please distinguish existing requirements, recommended practices, and questions reserved for individual project review. Where an issue falls outside this PEIS, identify a practical route for companion guidance or interagency work.
Thank you for considering these requests. My goal is responsible battery storage development supported by clear expectations that communities, responders, and project owners can put into practice.
Karl de Jong
Sedro-Woolley, Washington
References
[1] Washington Department of Ecology. Battery Energy Storage Systems PEIS Scoping Document, Publication 26-06-017, September 2026. Sections 1.3–1.4, pp. 11–12; Section 4, pp. 16–19; Sections 5.2–5.4, pp. 20–22.
https://apps.ecology.wa.gov/publications/documents/2606017.pdf
[2] U.S. Environmental Protection Agency. Battery Energy Storage Systems: Main Considerations for Safe Installation and Incident Response, EPA 530-F-25-013, July 2025, pp. 1–3.
https://www.epa.gov/system/files/documents/2025-08/battery_energy_storage_systems_fact_sheet.pdf
[3] UL Solutions. Installation Codes and Requirements for Energy Storage Systems (ESS) – FAQs. Accessed September 22, 2026.
https://www.ul.com/resources/installation-codes-and-requirements-energy-storage-systems-ess-faqs
[4] NYSERDA. New York Battery Energy Storage System Guidebook for Local Governments, November 2024. Advisory status, p. 1; model-law provisions, printed pp. 10–13.
https://www.nyserda.ny.gov/-/media/Project/Nyserda/files/Programs/clean-energy-siting/battery-storage-guidebook.pdf
[5] Washington Administrative Code, WAC 197-11-660, particularly subsection (1)(a)–(e).
https://app.leg.wa.gov/WAC/default.aspx?cite=197-11-660↓
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The scope of environmental health and safety concerns needs to be expanded to account for battery fires and the potential environmental fallout involved from the following:
1. High temperatures from thermal runaway increasing nearby stream temperatur...↓es and harming native species like salmonids.
2. Fire and response causing high turbidity, changes in dissolved oxygen or other stream quality issues.
3. Water availability for fire mitigation.
4. Secondary containment in case of water or chemicals or particulates used to put out fires.
5. Secondary containment in case of leaked materials or exposure of copper or other heavy metals to water and the resultant leaching or leaking of heavy metal contaminated liquid into nearby streams and groundwater.
6. Potential impact of floods. Here, mitigation is likely not possible and facilities should be forbidden in high flood-risk zones.
7. Secondary environmental effects caused by evacuation in the event of fire and/or thermal runaway or air and water contamination.
8. Effects of discontinued materials on the environment after exceeding their useful life or replacement for other reasons.
9. The specific effects on bald eagles, their reproductive and nesting patterns caused by the noise of an operational facility and by the potential fires associated with the facilities.
10. The potential effects on previously restored habitat and ecosystems in areas that underwent major projects to recover habitat such as salmon spawning, streambed and riparian improvements which did not anticipate large industrial facilities being cited in or near these areas.
11. Effects of increases impervious surface near streams not only during everyday operations but in the event of flood, battery fire, wildfire, etc.
12. Potential increased risk from any wildfire that might reach a battery facility.
↓
1. High temperatures from thermal runaway increasing nearby stream temperatur...↓es and harming native species like salmonids.
2. Fire and response causing high turbidity, changes in dissolved oxygen or other stream quality issues.
3. Water availability for fire mitigation.
4. Secondary containment in case of water or chemicals or particulates used to put out fires.
5. Secondary containment in case of leaked materials or exposure of copper or other heavy metals to water and the resultant leaching or leaking of heavy metal contaminated liquid into nearby streams and groundwater.
6. Potential impact of floods. Here, mitigation is likely not possible and facilities should be forbidden in high flood-risk zones.
7. Secondary environmental effects caused by evacuation in the event of fire and/or thermal runaway or air and water contamination.
8. Effects of discontinued materials on the environment after exceeding their useful life or replacement for other reasons.
9. The specific effects on bald eagles, their reproductive and nesting patterns caused by the noise of an operational facility and by the potential fires associated with the facilities.
10. The potential effects on previously restored habitat and ecosystems in areas that underwent major projects to recover habitat such as salmon spawning, streambed and riparian improvements which did not anticipate large industrial facilities being cited in or near these areas.
11. Effects of increases impervious surface near streams not only during everyday operations but in the event of flood, battery fire, wildfire, etc.
12. Potential increased risk from any wildfire that might reach a battery facility.
↓
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To the Department of Ecology, Clean Energy Coordination:
My name is Rachel McCall and I live at 7517 Pinnacle Pl SE, Snoqualmie, WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility...↓-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study.
This is personal for my household. I live within 2 miles from the proposed site. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
My comment addresses the following:
Q1 · Facility types: Which kinds of battery facilities get studied.
I would like the study to look at stand-alone sites near homes like mine, not the remote ones it studied before, which are frankly not very relevant to situations my neighborhood is facing. The study should picture rows of container-sized battery nestled in neighborhoods near homes, schools and playgrounds, because that is what is being proposed and how Ecology itself describes these sites. I ask that Ecology define the facility types studied to include large, container-based lithium-ion installations near residential areas, and that the analysis assume the fire codes currently in force in Washington, rely on independent safety data, and call for the newest safety standards as a condition of approval.
Q2 -- Where they get built.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Rachel McCall
7517 Pinnacle Pl SE, Snoqualmie, WA.↓
My name is Rachel McCall and I live at 7517 Pinnacle Pl SE, Snoqualmie, WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility...↓-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study.
This is personal for my household. I live within 2 miles from the proposed site. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
My comment addresses the following:
Q1 · Facility types: Which kinds of battery facilities get studied.
I would like the study to look at stand-alone sites near homes like mine, not the remote ones it studied before, which are frankly not very relevant to situations my neighborhood is facing. The study should picture rows of container-sized battery nestled in neighborhoods near homes, schools and playgrounds, because that is what is being proposed and how Ecology itself describes these sites. I ask that Ecology define the facility types studied to include large, container-based lithium-ion installations near residential areas, and that the analysis assume the fire codes currently in force in Washington, rely on independent safety data, and call for the newest safety standards as a condition of approval.
Q2 -- Where they get built.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Rachel McCall
7517 Pinnacle Pl SE, Snoqualmie, WA.↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Caitlin Hodges and I live in Snoqualmie Ridge. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-io...↓n battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
I would like the study to look at stand-alone sites near homes like mine, not the remote ones it studied before, since Ecology admits these sites are smaller and "could be sited in a variety of locations." The study should include the largest container-style installations now being proposed near neighborhoods, not just small substation batteries, since Ecology has not yet decided what kind of facility it will study. The study should picture rows of container-sized battery boxes beside homes and schools, because that is what is being proposed and how Ecology itself describes these sites. The study should assume facilities would be built to the rules Washington has actually adopted, and say what the newest standards would change, since Ecology admits the state's fire code is behind them. I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the code Washington has actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live 1–2 miles from the proposed site. My children go to school nearby, at Timber Ridge Elementary. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Caitlin Hodges
Snoqualmie Ridge Resident↓
My name is Caitlin Hodges and I live in Snoqualmie Ridge. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-io...↓n battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
I would like the study to look at stand-alone sites near homes like mine, not the remote ones it studied before, since Ecology admits these sites are smaller and "could be sited in a variety of locations." The study should include the largest container-style installations now being proposed near neighborhoods, not just small substation batteries, since Ecology has not yet decided what kind of facility it will study. The study should picture rows of container-sized battery boxes beside homes and schools, because that is what is being proposed and how Ecology itself describes these sites. The study should assume facilities would be built to the rules Washington has actually adopted, and say what the newest standards would change, since Ecology admits the state's fire code is behind them. I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the code Washington has actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live 1–2 miles from the proposed site. My children go to school nearby, at Timber Ridge Elementary. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Caitlin Hodges
Snoqualmie Ridge Resident↓
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To the Department of Ecology, Clean Energy Coordination:
My name is Matthew Prall and I live at 7405 Dogwood Ln SE, Snoqualmie, WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-...↓scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
I would like the study to look at stand-alone sites near homes like mine, not the remote ones it studied before, since Ecology admits these sites are smaller and "could be sited in a variety of locations." The study should include the largest container-style installations now being proposed near neighborhoods, not just small substation batteries, since Ecology has not yet decided what kind of facility it will study. I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the code Washington has actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation.
Q2 · Geographic scope — Where the study assumes batteries will go.
Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
This is personal for my household. I live under 1 mile from the proposed site. My children go to school nearby, at Cascade View Elementary. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Matthew Prall
7405 Dogwood Ln SE, Snoqualmie, WA↓
My name is Matthew Prall and I live at 7405 Dogwood Ln SE, Snoqualmie, WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-...↓scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
I would like the study to look at stand-alone sites near homes like mine, not the remote ones it studied before, since Ecology admits these sites are smaller and "could be sited in a variety of locations." The study should include the largest container-style installations now being proposed near neighborhoods, not just small substation batteries, since Ecology has not yet decided what kind of facility it will study. I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the code Washington has actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation.
Q2 · Geographic scope — Where the study assumes batteries will go.
Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
This is personal for my household. I live under 1 mile from the proposed site. My children go to school nearby, at Cascade View Elementary. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Matthew Prall
7405 Dogwood Ln SE, Snoqualmie, WA↓
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To the Department of Ecology, Clean Energy Coordination:
My name is Jessica Moylan and I live at 7903 Cortland Ave SE Snoqualmie WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, u...↓tility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's geographic assumptions should screen out places with private wells, floodplains, earthquake faults, and neighborhoods with one road out, because site details will be left to later reviews. The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study should look at what a multi-day battery fire demands from local fire, hazmat, hospital, and evacuation capacity, since Ecology could not say whether the burden on small rural fire districts can be fixed. I would like to see the study thoroughly examine the direct, indirect, and cumulative effects of how smoke settles into valleys, runoff reaches wells and streams, and what happens when there are several facilities on the same stretch of grid. The study should properly model whether neighbors can evacuate without breathing dangerous levels of toxic gas in places such as a valley that traps air, which is what the fire code requires. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
The study should be specific enough to give local reviewers something to hold a developer to, because my county will lean on it when it reviews a real project. The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. The study should recommend large-scale fire testing be required for every facility, whether or not the state has adopted the newest code, since Ecology itself credits it with reducing risk. The study should recommend developer-funded monitoring, cleanup guarantees, and decommissioning bonds, as state rules already require these for other energy facilities. The study should state that local governments may require stronger protections than the state minimum. State standards should be a floor, not a ceiling. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live less than one mile from the proposed site. My son currently go to Pre-K nearby, at Timber Ridge Elementary. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Jessica Moylan
↓
My name is Jessica Moylan and I live at 7903 Cortland Ave SE Snoqualmie WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, u...↓tility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's geographic assumptions should screen out places with private wells, floodplains, earthquake faults, and neighborhoods with one road out, because site details will be left to later reviews. The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study should look at what a multi-day battery fire demands from local fire, hazmat, hospital, and evacuation capacity, since Ecology could not say whether the burden on small rural fire districts can be fixed. I would like to see the study thoroughly examine the direct, indirect, and cumulative effects of how smoke settles into valleys, runoff reaches wells and streams, and what happens when there are several facilities on the same stretch of grid. The study should properly model whether neighbors can evacuate without breathing dangerous levels of toxic gas in places such as a valley that traps air, which is what the fire code requires. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
The study should be specific enough to give local reviewers something to hold a developer to, because my county will lean on it when it reviews a real project. The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. The study should recommend large-scale fire testing be required for every facility, whether or not the state has adopted the newest code, since Ecology itself credits it with reducing risk. The study should recommend developer-funded monitoring, cleanup guarantees, and decommissioning bonds, as state rules already require these for other energy facilities. The study should state that local governments may require stronger protections than the state minimum. State standards should be a floor, not a ceiling. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live less than one mile from the proposed site. My son currently go to Pre-K nearby, at Timber Ridge Elementary. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Jessica Moylan
↓
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To the Washington State Department of Ecology:
I appreciate the opportunity to provide comments regarding the development of the Battery Energy Storage Systems (BESS) Programmatic Environmental Impact Statement.
As Washington evaluates the environm...↓ental impacts and safety considerations associated with the growing deployment of battery energy storage systems, I encourage the Department to recognize and evaluate advanced fire protection technologies that can reduce both environmental risks and public safety concerns. One such technology is F-500 Encapsulator Agent (F-500 EA®).
F-500 EA is a fluorine-free, biodegradable fire suppression and hazard mitigation agent that has demonstrated effectiveness in lithium-ion battery fire incidents. Unlike traditional firefighting foams that may contain persistent PFAS compounds, F-500 EA contains no fluorinated active ingredients and is designed to be non-toxic, non-corrosive, and readily biodegradable. These characteristics can help reduce the potential for long-term environmental contamination associated with fire suppression activities.
For battery energy storage systems, F-500 EA offers several capabilities that are particularly relevant to the environmental and safety objectives of the Programmatic EIS:
Thermal runaway mitigation: F-500 EA is specifically designed to rapidly cool lithium-ion batteries and surrounding equipment, helping to interrupt thermal runaway events and reduce the likelihood of fire propagation between cells and battery modules.
Reduced water usage: Because the agent improves heat transfer and cooling efficiency, significantly less water may be required during fire suppression activities compared with conventional methods. Reduced water usage can decrease contaminated runoff and lessen demands on local water resources.
Reduction of smoke and toxic byproducts: By encapsulating hydrocarbons and combustion products, F-500 EA can help reduce smoke, airborne contaminants, and hazardous emissions generated during battery fires, potentially improving conditions for first responders and surrounding communities.
PFAS-free environmental profile: As state and federal agencies continue to address concerns regarding PFAS contamination, the use of fluorine-free suppression technologies should be encouraged where technically appropriate. F-500 EA provides an alternative that aligns with broader environmental protection goals.
Compatibility with modern energy infrastructure: F-500 EA can be integrated into fire protection strategies for utility-scale and commercial battery storage installations, supporting safer deployment of energy storage systems that are essential for renewable energy integration and grid reliability.
As the Department evaluates alternatives, mitigation measures, and best management practices for BESS facilities, I encourage consideration of advanced suppression technologies such as F-500 EA that can reduce environmental impacts while improving fire safety outcomes.
Washington's transition to cleaner energy resources should be accompanied by equally progressive approaches to risk reduction, environmental protection, and emergency response planning. Including consideration of F-500 EA in the Programmatic EIS would help provide a more complete evaluation of available mitigation measures for battery energy storage facilities.
I have uploaded files that include SDS's, Technical Data Sheets, and other informative information regarding the capabilities, safety, and environmental benefits of F-500 EA.
Thank you for your consideration of these comments and please feel free to reach out to me via email for more information.
Sincerely,
Michael Cusumano
Regional Sales Manager
Creation Organics LLC. (Sole Distributor in WA and OR of F-500 EA)
mcusumano@creationorganics.com
↓
I appreciate the opportunity to provide comments regarding the development of the Battery Energy Storage Systems (BESS) Programmatic Environmental Impact Statement.
As Washington evaluates the environm...↓ental impacts and safety considerations associated with the growing deployment of battery energy storage systems, I encourage the Department to recognize and evaluate advanced fire protection technologies that can reduce both environmental risks and public safety concerns. One such technology is F-500 Encapsulator Agent (F-500 EA®).
F-500 EA is a fluorine-free, biodegradable fire suppression and hazard mitigation agent that has demonstrated effectiveness in lithium-ion battery fire incidents. Unlike traditional firefighting foams that may contain persistent PFAS compounds, F-500 EA contains no fluorinated active ingredients and is designed to be non-toxic, non-corrosive, and readily biodegradable. These characteristics can help reduce the potential for long-term environmental contamination associated with fire suppression activities.
For battery energy storage systems, F-500 EA offers several capabilities that are particularly relevant to the environmental and safety objectives of the Programmatic EIS:
Thermal runaway mitigation: F-500 EA is specifically designed to rapidly cool lithium-ion batteries and surrounding equipment, helping to interrupt thermal runaway events and reduce the likelihood of fire propagation between cells and battery modules.
Reduced water usage: Because the agent improves heat transfer and cooling efficiency, significantly less water may be required during fire suppression activities compared with conventional methods. Reduced water usage can decrease contaminated runoff and lessen demands on local water resources.
Reduction of smoke and toxic byproducts: By encapsulating hydrocarbons and combustion products, F-500 EA can help reduce smoke, airborne contaminants, and hazardous emissions generated during battery fires, potentially improving conditions for first responders and surrounding communities.
PFAS-free environmental profile: As state and federal agencies continue to address concerns regarding PFAS contamination, the use of fluorine-free suppression technologies should be encouraged where technically appropriate. F-500 EA provides an alternative that aligns with broader environmental protection goals.
Compatibility with modern energy infrastructure: F-500 EA can be integrated into fire protection strategies for utility-scale and commercial battery storage installations, supporting safer deployment of energy storage systems that are essential for renewable energy integration and grid reliability.
As the Department evaluates alternatives, mitigation measures, and best management practices for BESS facilities, I encourage consideration of advanced suppression technologies such as F-500 EA that can reduce environmental impacts while improving fire safety outcomes.
Washington's transition to cleaner energy resources should be accompanied by equally progressive approaches to risk reduction, environmental protection, and emergency response planning. Including consideration of F-500 EA in the Programmatic EIS would help provide a more complete evaluation of available mitigation measures for battery energy storage facilities.
I have uploaded files that include SDS's, Technical Data Sheets, and other informative information regarding the capabilities, safety, and environmental benefits of F-500 EA.
Thank you for your consideration of these comments and please feel free to reach out to me via email for more information.
Sincerely,
Michael Cusumano
Regional Sales Manager
Creation Organics LLC. (Sole Distributor in WA and OR of F-500 EA)
mcusumano@creationorganics.com
↓
To the Department of Ecology, Clean Energy Coordination:
My name is Sean Smith and I live at 15825 SE 258th Street, Covington, WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-s...↓cale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the code Washington has actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation.
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Snoqualmie Valley's conditions should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I am a Natural Resource Manager/Environmental Planner, and I offer this comment with that professional background.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Sean Smith
15825 SE 258th Street
Covington, WA 98042↓
My name is Sean Smith and I live at 15825 SE 258th Street, Covington, WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-s...↓cale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the code Washington has actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation.
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Snoqualmie Valley's conditions should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I am a Natural Resource Manager/Environmental Planner, and I offer this comment with that professional background.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Sean Smith
15825 SE 258th Street
Covington, WA 98042↓
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To the Department of Ecology, Clean Energy Coordination:
My name is Joanne Dyer, and I live at 34602 Cottonwood Dr SE in Snoqualmie, Washington. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-al...↓one, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
Jupiter Energy has proposed a BESS facility on Snoqualmie Ridge, a short walk from my home. My comment addresses the harms the study is required to consider.
The state must consider what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs, but it does not mention neighbors who have no protective gear or training, and who may not be able to safely leave in time.
I ask that the PEIS analyze, for stand-alone facilities such as the one proposed by my home: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys such as my neighborhood; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; and seismic performance of container-based installations in mapped fault zones.
In an emergency such as a BESS fire, my husband, pets, and I would evacuate via Snoqualmie Parkway and I-90 west, along with everyone else who depends on those roads.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume these facilities will be far enough away from people to ensure the safety of communities. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record.
Sincerely,
JoAnne Dyer
34602 Cottonwood Dr Se
Snoqualmie, Washington 98065
↓
My name is Joanne Dyer, and I live at 34602 Cottonwood Dr SE in Snoqualmie, Washington. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-al...↓one, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
Jupiter Energy has proposed a BESS facility on Snoqualmie Ridge, a short walk from my home. My comment addresses the harms the study is required to consider.
The state must consider what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs, but it does not mention neighbors who have no protective gear or training, and who may not be able to safely leave in time.
I ask that the PEIS analyze, for stand-alone facilities such as the one proposed by my home: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys such as my neighborhood; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; and seismic performance of container-based installations in mapped fault zones.
In an emergency such as a BESS fire, my husband, pets, and I would evacuate via Snoqualmie Parkway and I-90 west, along with everyone else who depends on those roads.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume these facilities will be far enough away from people to ensure the safety of communities. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record.
Sincerely,
JoAnne Dyer
34602 Cottonwood Dr Se
Snoqualmie, Washington 98065
↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Charles Vision and I live at 34602 Cottonwood Dr SE, Snoqualmie, WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alon...↓e, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017). I have a master's degree in Mechanical engineer and have 30 years of experience specializing in failure analysis, and I offer this comment with that professional background.
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
The study should assume companies will build facilities to the exact rules Washington has actually adopted. So, the rules should be updated regularly to the latest standards as they are being modified as failures occur and the states learn more about the issues. This technology is quite young and changing regularly so the state should be ready to revise their rules to keep up with the technology. The study should also use independent safety data rather than just relying on a limited set of failure data being documented by EPRI. As EPRI has stated many times in their database, their failure data is inadequate since no laws on the state or federal level require companies to admit when failures occur that do not make the news. Unless we force the companies to document all failures, we will never know the full scale of what issues this technology poses.
This study also needs to look at the effect of evacuations and cleanup since the closer these sites are to homes, the more this will dramatically affect the neighborhoods. I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the code Washington has actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation.
This is personal for my household. I live under 1 mile from the proposed site. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Charles Vision
34602 Cottonwood Dr SE, Snoqualmie, WA 98065↓
My name is Charles Vision and I live at 34602 Cottonwood Dr SE, Snoqualmie, WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alon...↓e, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017). I have a master's degree in Mechanical engineer and have 30 years of experience specializing in failure analysis, and I offer this comment with that professional background.
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
The study should assume companies will build facilities to the exact rules Washington has actually adopted. So, the rules should be updated regularly to the latest standards as they are being modified as failures occur and the states learn more about the issues. This technology is quite young and changing regularly so the state should be ready to revise their rules to keep up with the technology. The study should also use independent safety data rather than just relying on a limited set of failure data being documented by EPRI. As EPRI has stated many times in their database, their failure data is inadequate since no laws on the state or federal level require companies to admit when failures occur that do not make the news. Unless we force the companies to document all failures, we will never know the full scale of what issues this technology poses.
This study also needs to look at the effect of evacuations and cleanup since the closer these sites are to homes, the more this will dramatically affect the neighborhoods. I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the code Washington has actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation.
This is personal for my household. I live under 1 mile from the proposed site. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Charles Vision
34602 Cottonwood Dr SE, Snoqualmie, WA 98065↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Preston Rutherford and I live at 34328 SE Graves Street. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, ...↓lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. The study should state that local governments may require stronger protections than the state minimum. State standards should be a floor, not a ceiling. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live 1–2 miles from the proposed site. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Preston Rutherford
34328 SE Graves Street↓
My name is Preston Rutherford and I live at 34328 SE Graves Street. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, ...↓lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. The study should state that local governments may require stronger protections than the state minimum. State standards should be a floor, not a ceiling. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live 1–2 miles from the proposed site. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Preston Rutherford
34328 SE Graves Street↓
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The Department of Ecology deserves to be commended for its commitment to evaluate battery energy storage systems (BESS). The cost of BESS has declined dramatically as their technical viability has improved. Today the U.S. has more than 1,000 one-meg...↓awatt or larger BESSs representing over 50,000 megawatts of capacity with another 70,000 additional megawatts in development.
During your scoping study you should consider the following items:
1) Examining BESS technologies beyond just the traditional lithium-ion chemistries.
2) Carefully reviewing existing assessments and experiences from the large-scale deployment of these systems in states such as Texas and California
3) Allowing a wide range of input from groups and individuals who both support and oppose BESS deployment.
4) Conducing a details analysis of proven strategies which mitigate potential impacts of BESS.
5) Identification of ways to broadly educate Washington citizens on the BESS system characteristics, impacts, and benefits.
I look forward to seeing the results of your work,
Thank you for the opportunity to comment.↓
During your scoping study you should consider the following items:
1) Examining BESS technologies beyond just the traditional lithium-ion chemistries.
2) Carefully reviewing existing assessments and experiences from the large-scale deployment of these systems in states such as Texas and California
3) Allowing a wide range of input from groups and individuals who both support and oppose BESS deployment.
4) Conducing a details analysis of proven strategies which mitigate potential impacts of BESS.
5) Identification of ways to broadly educate Washington citizens on the BESS system characteristics, impacts, and benefits.
I look forward to seeing the results of your work,
Thank you for the opportunity to comment.↓
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It's critical that the state take into account the newest battery chemistries that have vastly lower to almost no fire risk. The fires from five years ago aren't possible given how today's BESS systems are designed, built and integrated. These newer ...↓systems are also much quieter or effectively silent. BESS systems are key to keeping electricity rates from skyrocketing, keep the lights on during extreme heat or cold, and to allow large power users like ports, stadiums, hospitals, and manufacturers to manage their onsite power usage and backup critical systems.↓
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To the Department of Ecology, Clean Energy Coordination:
My name is K. Natarajan and I live at 7720 Greenridge Ct SE, Snoqualmie, WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, ...↓utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
As a former Big Pharma global public policy and government affairs executive, I know how a wholly-owned Blackrock private equity holding company like Jupiter Power LLC operates. Take a note that they have steamrolled over some city/town political leaders and paid lobbyists like 360 Strategies to draft King Co. Chairwoman Sarah Perry's BESS ordinances (the PRRs have revealed shocking corruption). Your study must assess stand-alone sites near homes like mine, not the remote ones it studied before, since Ecology admits these sites are smaller and "could be sited in a variety of locations." The study should include the largest container-style installations now being proposed near neighborhoods, not just small substation batteries, since Ecology has not yet decided what kind of facility it will study. The study should picture rows of container-sized battery boxes beside homes and schools, because that is what is being proposed and how Ecology itself describes these sites. The study should assume facilities would be built to the rules Washington has actually adopted, and say what the newest standards would change, since Ecology admits the state's fire code is behind them. I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the code Washington has actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation.
Q2 · Geographic scope — Where the study assumes batteries will go.
Close proximity to existing infrastructure (particular when it's adjacent or on protected wetlands and/or Snoqualmie Tribal lands) should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Snoqualmie Valley's conditions should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I would like the study to name specific, measurable protections a permit can require. Protections described "at a high level" give my county nothing to write into a permit. The study should be specific enough to give local reviewers something to hold a developer to, because my county will lean on it when it reviews a real project. The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. The study should recommend large-scale fire testing be required for every facility, whether or not the state has adopted the newest code, since Ecology itself credits it with reducing risk. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live under 1 mile from the proposed site. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road. As a public health professional and WHO Expert Adviser (MSc from Harvard) with an undergraduate degree in Industrial Engineering and years of experience manufacturing vaccines and bulk chemical pharmaceuticals in highly regulated environments. I offer my comments with that professional background.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
K. Natarajan
7720 Greenridge Ct SE
Snoqualmie, WA 98065↓
My name is K. Natarajan and I live at 7720 Greenridge Ct SE, Snoqualmie, WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, ...↓utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
As a former Big Pharma global public policy and government affairs executive, I know how a wholly-owned Blackrock private equity holding company like Jupiter Power LLC operates. Take a note that they have steamrolled over some city/town political leaders and paid lobbyists like 360 Strategies to draft King Co. Chairwoman Sarah Perry's BESS ordinances (the PRRs have revealed shocking corruption). Your study must assess stand-alone sites near homes like mine, not the remote ones it studied before, since Ecology admits these sites are smaller and "could be sited in a variety of locations." The study should include the largest container-style installations now being proposed near neighborhoods, not just small substation batteries, since Ecology has not yet decided what kind of facility it will study. The study should picture rows of container-sized battery boxes beside homes and schools, because that is what is being proposed and how Ecology itself describes these sites. The study should assume facilities would be built to the rules Washington has actually adopted, and say what the newest standards would change, since Ecology admits the state's fire code is behind them. I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the code Washington has actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation.
Q2 · Geographic scope — Where the study assumes batteries will go.
Close proximity to existing infrastructure (particular when it's adjacent or on protected wetlands and/or Snoqualmie Tribal lands) should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Snoqualmie Valley's conditions should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I would like the study to name specific, measurable protections a permit can require. Protections described "at a high level" give my county nothing to write into a permit. The study should be specific enough to give local reviewers something to hold a developer to, because my county will lean on it when it reviews a real project. The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. The study should recommend large-scale fire testing be required for every facility, whether or not the state has adopted the newest code, since Ecology itself credits it with reducing risk. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live under 1 mile from the proposed site. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road. As a public health professional and WHO Expert Adviser (MSc from Harvard) with an undergraduate degree in Industrial Engineering and years of experience manufacturing vaccines and bulk chemical pharmaceuticals in highly regulated environments. I offer my comments with that professional background.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
K. Natarajan
7720 Greenridge Ct SE
Snoqualmie, WA 98065↓
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Unless this actively regenerates or supports the landscape we do not want it . The red flags of having this near our families out weighs the finances that fund it. Auburn doesn't need or want more on its shoulders . Out of all of WA you have so many ...↓other places to place a lithium storage facility where fires and water run off don't harm surrounding neighbors .↓
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SCOPING COMMENT
Programmatic Environmental Impact Statement for Stand-Alone, Utility-Scale Lithium-Ion
Battery Energy Storage Systems
Publication 26-06-017
Submitted to: Washington State Department of Ecology, Clean Energy Coordination
Submitted by: ...↓Henrika Stich
Address: 36702 SE Gravenstein Ct.
Subject: Formal Scoping Comment on the Programmatic Environmental Impact Statement
To the Department of Ecology, Clean Energy Coordination:
My name is Henrika Stich, and I reside at 36702 SE Gravenstein Ct. I respectfully submit this scoping
comment concerning the Programmatic Environmental Impact Statement (PEIS) for stand-alone, utilityscale
lithium-ion battery energy storage system (BESS) facilities in Washington, identified as Publication
26-06-017.
This comment is submitted because a stand-alone BESS facility has been proposed in the Snoqualmie
Valley, and the Department of Ecology has indicated that subsequent project -level environmental
reviews will tier from this PEIS. Because Ecology has requested public input regarding the questions and
matters that should be addressed in the study, I request that the scope of the PEIS include the issues
set forth below.
Q1. Categories of Battery Facilities to Be Evaluated
The PEIS should evaluate stand-alone BESS facilities proposed near residences and other sensitive
receptors, rather than limiting its analysis to remote facilities of the type previously studied. Ecology has
acknowledged that these facilities may be smaller and "could be sited in a variety of locations."
Accordingly, the study should encompass the largest containerized installations currently being
proposed near residential neighborhoods and should not be limited to small battery installations
located at substations.
The PEIS should depict and evaluate the reasonably foreseeable configuration of multiple container -
sized battery units located near homes and schools, because such configurations are currently being
proposed and are consistent with Ecology's own description of these facilities. The analysis should
evaluate facilities as constructed pursuant to the codes and standards presently adopted in
Washington and should expressly identify how more recent safety standards would alter the anticipated
risks and impacts, particularly in light of Ecology's acknowledgment that the State fire code does not
incorporate the most current standards.
The PEIS should identify the safest current standard and evaluate it as the appropriate mitigation
baseline for all facilities, recognizing that local safety requirements vary among jurisdictions. The
analysis should rely upon independent safety data and should treat evacuation, displacement,
environmental remediation, and cleanup as impacts in their own right, rather than limiting the
assessment to the occurrence of a fire or relying primarily upon failure data produced by an industry -
funded research institution.
For these reasons, I request that the PEIS evaluate the full range of stand-alone facilities reasonably
anticipated to be proposed in Washington, including large, container -based lithium-ion installations located near residences, schools, and constrained transportation networks. The PEIS should analyze
such facilities under the codes adopted by Washington, rely upon independent safety data rather than
industry assurances, and identify compliance with the most recent safety standards as required for
mitigation.
Q2. Siting Assumptions and Areas to Be Evaluated
The PEIS should define "suitable" areas by reference to public safety and the protection of affected
communities, not merely by whether a facility can be physically constructed at a particular location.
Proximity to existing electrical infrastructure, including substations, should not be treated as a
substitute for a site-specific determination of suitability and safety.
The geographic analysis should identify locations where stand-alone BESS facilities should not be sited,
rather than only mapping locations where development may be technically feasible. The conditions
present in the Snoqualmie Valley should be included in the study's geographic assumptions before
Ecology establishes the final study area. Those assumptions should screen for locations involving
private wells, floodplains, seismic faults, and residential communities dependent upon limited
evacuation routes, particularly because detailed site-specific conditions may otherwise be deferred to
later project-level review.
The geographic analysis should also account for wildfire exposure and the capacity of local fire districts.
Ecology's prior studies identified wildfire risk associated with "new ignition sources in remote locations
with limited response capabilities." Ecology has also committed to receiving input from local
communities. Accordingly, the PEIS should consider the knowledge and concerns of the residents who
would be directly affected by these sitting decisions.
I therefore request that the PEIS expressly account for proximity to homes, schools, and hospitals;
wildland-urban interface and wildfire-prone areas; mapped seismic hazard zones and floodplains;
areas dependent upon private wells; and communities with limited evacuation routes. Proximity to
existing infrastructure should not, by itself, be deemed evidence that a site is suitable.
Q3. Environmental Impacts Requiring Full Analysis
The PEIS should provide a complete and substantive analysis of responder training needs, fires that are
difficult to extinguish, toxic air emissions, impacts on water and fish, and post-incident remediation and
cleanup. These matters should not be addressed only in passing, particularly because Ecology's
scoping document states that the PEIS "will evaluate" each of them.
The PEIS should model the dispersion and public-health consequences of smoke and hazardous gases
generated by a battery fire for persons residing near a facility. Although the scoping document
recognizes that toxic gases released from damaged batteries may injure firefighters' skin and lungs,
neighboring residents have no protective equipment and may be unable to evacuate promptly.
Evacuation, displacement, and offsite remediation should therefore be evaluated as separate and
material impacts. Ecology's own example involving the Moss Landing fire states that 1,200 people were
displaced from their homes.
The PEIS should evaluate continuous and maximum nighttime noise at the nearest residence, rather
than solely at the facility boundary. Ecology's prior studies found that noise associated with these
facilities may extend 1,000 feet in quiet rural areas. The PEIS should also evaluate the operational
burden that a multi-day battery fire would place upon local fire, hazardous-materials response,hospital, and evacuation capacity, particularly where Ecology has not determined whether the resulting
burden on small rural fire districts can be adequately mitigated.
At a minimum, the PEIS should analyze: (1) thermal-runaway fires and hazardous-gas emissions,
including hydrogen fluoride, using dispersion modeling appropriate for inversion-prone valleys; (2)
contaminated fire-suppression water and its potential migration to groundwater, private wells, and fishbearing
streams; (3) demands created by multi-day incidents upon local fire, HazMat, hospital, and
evacuation resources; (4) continuous nighttime noise from cooling equipment and inverters at
distances exceeding 1,000 feet; and (5) the seismic performance of container-based installations
located within mapped fault zones.
Q4. Mitigation Measures and Steps
The PEIS should identify specific, measurable, and enforceable mitigation measures capable of
incorporation into project permits. Mitigation described only "at a high level" would not provide local
jurisdictions with sufficiently definite standards for permit conditions or enforcement. Because local
reviewing agencies are expected to rely upon the PEIS when evaluating individual projects, its
recommended protections should be sufficiently precise to establish objective requirements for project
applicants.
The siting and design recommendations should include minimum protective setbacks from homes,
schools, hospitals, and drinking-water wells, supported by evidence demonstrating that the distances
are protective of the surrounding community. General guidance, without measurable criteria, is
insufficient. The PEIS should also recommend large-scale fire testing for every facility, regardless of
whether Washington has yet adopted the latest code edition, because Ecology has recognized that such
testing reduces risk.
The PEIS should further make clear that any statewide siting, design, or operational standards establish
minimum requirements only and do not preempt or otherwise restrict a local jurisdiction from imposing
more protective measures when warranted by site-specific conditions. State standards should
therefore operate as a regulatory floor, not a ceiling. In addition, the PEIS should recommend
enforceable, developer-funded obligations for ongoing environmental and safety monitoring, post -
incident investigation and remediation, financial assurances for cleanup, and decommissioning
security, including bonds or equivalent instruments sufficient to ensure that the costs of closure,
removal, restoration, and remediation are borne by the facility owner or operator rather than affected
communities or public agencies. Such financial-assurance measures should be evaluated in light of
analogous requirements applicable to other energy facilities under existing state regulatory programs.
The PEIS should specify the measures necessary to reduce wildfire and emergency-response impacts,
including fully funded training and equipment for local responders before a facility becomes
operational. Where a material impact cannot be reduced to an acceptable level, including a fire beyond
the containment capacity of a small rural fire district, the PEIS should clearly identify that impact as
unavoidable rather than presuming that mitigation will be adequate.
I therefore request that the PEIS identify, at a minimum, the following mitigation requirements:
minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing in
accordance with UL 9540A; compliance with the current edition of NFPA 855 regardless of State
adoption status; funded emergency-response plans, training, and equipment for local fire districts
before operation; containment and lawful disposal plans for contaminated fire-suppression water;enforceable nighttime noise limits measured at the nearest residence; and enforceable
decommissioning and financial-assurance requirements.
Site-Specific Community Considerations
The matters identified above directly affect my household. My residence is located less than one mile
from the proposed site. My children attend Snoqualmie Middle School nearby. In the event of an
emergency, my household would be required to evacuate by way of Snoqualmie Parkway, together with
other residents who depend upon the same roadway.
Because Ecology has stated that stand-alone facilities "could be sited in a variety of locations,"
including locations near cities, the PEIS should not assume that these facilities will be remote from
population centers. Proximity to residents should be treated as a defining condition of environmental
analysis. The Draft PEIS should clearly identify any significant impacts that cannot be reduced below
the applicable significance threshold so that lead agencies and the public are not left to speculate
regarding the nature or severity of unresolved impacts.
Request for Inclusion in the Scoping Record
Thank you for considering this comment. I respectfully request that it be included in the official scoping
record. The affected community is closely following the development of this PEIS and intends to
participate in the public-comment process for the Draft PEIS.
Respectfully submitted,
HENRIKA STICH
36702 SE GRAVENSTEIN CT
SNOQUALMIE WA 98065
206-234-4705
henrika.stich@outlook.com↓
Programmatic Environmental Impact Statement for Stand-Alone, Utility-Scale Lithium-Ion
Battery Energy Storage Systems
Publication 26-06-017
Submitted to: Washington State Department of Ecology, Clean Energy Coordination
Submitted by: ...↓Henrika Stich
Address: 36702 SE Gravenstein Ct.
Subject: Formal Scoping Comment on the Programmatic Environmental Impact Statement
To the Department of Ecology, Clean Energy Coordination:
My name is Henrika Stich, and I reside at 36702 SE Gravenstein Ct. I respectfully submit this scoping
comment concerning the Programmatic Environmental Impact Statement (PEIS) for stand-alone, utilityscale
lithium-ion battery energy storage system (BESS) facilities in Washington, identified as Publication
26-06-017.
This comment is submitted because a stand-alone BESS facility has been proposed in the Snoqualmie
Valley, and the Department of Ecology has indicated that subsequent project -level environmental
reviews will tier from this PEIS. Because Ecology has requested public input regarding the questions and
matters that should be addressed in the study, I request that the scope of the PEIS include the issues
set forth below.
Q1. Categories of Battery Facilities to Be Evaluated
The PEIS should evaluate stand-alone BESS facilities proposed near residences and other sensitive
receptors, rather than limiting its analysis to remote facilities of the type previously studied. Ecology has
acknowledged that these facilities may be smaller and "could be sited in a variety of locations."
Accordingly, the study should encompass the largest containerized installations currently being
proposed near residential neighborhoods and should not be limited to small battery installations
located at substations.
The PEIS should depict and evaluate the reasonably foreseeable configuration of multiple container -
sized battery units located near homes and schools, because such configurations are currently being
proposed and are consistent with Ecology's own description of these facilities. The analysis should
evaluate facilities as constructed pursuant to the codes and standards presently adopted in
Washington and should expressly identify how more recent safety standards would alter the anticipated
risks and impacts, particularly in light of Ecology's acknowledgment that the State fire code does not
incorporate the most current standards.
The PEIS should identify the safest current standard and evaluate it as the appropriate mitigation
baseline for all facilities, recognizing that local safety requirements vary among jurisdictions. The
analysis should rely upon independent safety data and should treat evacuation, displacement,
environmental remediation, and cleanup as impacts in their own right, rather than limiting the
assessment to the occurrence of a fire or relying primarily upon failure data produced by an industry -
funded research institution.
For these reasons, I request that the PEIS evaluate the full range of stand-alone facilities reasonably
anticipated to be proposed in Washington, including large, container -based lithium-ion installations located near residences, schools, and constrained transportation networks. The PEIS should analyze
such facilities under the codes adopted by Washington, rely upon independent safety data rather than
industry assurances, and identify compliance with the most recent safety standards as required for
mitigation.
Q2. Siting Assumptions and Areas to Be Evaluated
The PEIS should define "suitable" areas by reference to public safety and the protection of affected
communities, not merely by whether a facility can be physically constructed at a particular location.
Proximity to existing electrical infrastructure, including substations, should not be treated as a
substitute for a site-specific determination of suitability and safety.
The geographic analysis should identify locations where stand-alone BESS facilities should not be sited,
rather than only mapping locations where development may be technically feasible. The conditions
present in the Snoqualmie Valley should be included in the study's geographic assumptions before
Ecology establishes the final study area. Those assumptions should screen for locations involving
private wells, floodplains, seismic faults, and residential communities dependent upon limited
evacuation routes, particularly because detailed site-specific conditions may otherwise be deferred to
later project-level review.
The geographic analysis should also account for wildfire exposure and the capacity of local fire districts.
Ecology's prior studies identified wildfire risk associated with "new ignition sources in remote locations
with limited response capabilities." Ecology has also committed to receiving input from local
communities. Accordingly, the PEIS should consider the knowledge and concerns of the residents who
would be directly affected by these sitting decisions.
I therefore request that the PEIS expressly account for proximity to homes, schools, and hospitals;
wildland-urban interface and wildfire-prone areas; mapped seismic hazard zones and floodplains;
areas dependent upon private wells; and communities with limited evacuation routes. Proximity to
existing infrastructure should not, by itself, be deemed evidence that a site is suitable.
Q3. Environmental Impacts Requiring Full Analysis
The PEIS should provide a complete and substantive analysis of responder training needs, fires that are
difficult to extinguish, toxic air emissions, impacts on water and fish, and post-incident remediation and
cleanup. These matters should not be addressed only in passing, particularly because Ecology's
scoping document states that the PEIS "will evaluate" each of them.
The PEIS should model the dispersion and public-health consequences of smoke and hazardous gases
generated by a battery fire for persons residing near a facility. Although the scoping document
recognizes that toxic gases released from damaged batteries may injure firefighters' skin and lungs,
neighboring residents have no protective equipment and may be unable to evacuate promptly.
Evacuation, displacement, and offsite remediation should therefore be evaluated as separate and
material impacts. Ecology's own example involving the Moss Landing fire states that 1,200 people were
displaced from their homes.
The PEIS should evaluate continuous and maximum nighttime noise at the nearest residence, rather
than solely at the facility boundary. Ecology's prior studies found that noise associated with these
facilities may extend 1,000 feet in quiet rural areas. The PEIS should also evaluate the operational
burden that a multi-day battery fire would place upon local fire, hazardous-materials response,hospital, and evacuation capacity, particularly where Ecology has not determined whether the resulting
burden on small rural fire districts can be adequately mitigated.
At a minimum, the PEIS should analyze: (1) thermal-runaway fires and hazardous-gas emissions,
including hydrogen fluoride, using dispersion modeling appropriate for inversion-prone valleys; (2)
contaminated fire-suppression water and its potential migration to groundwater, private wells, and fishbearing
streams; (3) demands created by multi-day incidents upon local fire, HazMat, hospital, and
evacuation resources; (4) continuous nighttime noise from cooling equipment and inverters at
distances exceeding 1,000 feet; and (5) the seismic performance of container-based installations
located within mapped fault zones.
Q4. Mitigation Measures and Steps
The PEIS should identify specific, measurable, and enforceable mitigation measures capable of
incorporation into project permits. Mitigation described only "at a high level" would not provide local
jurisdictions with sufficiently definite standards for permit conditions or enforcement. Because local
reviewing agencies are expected to rely upon the PEIS when evaluating individual projects, its
recommended protections should be sufficiently precise to establish objective requirements for project
applicants.
The siting and design recommendations should include minimum protective setbacks from homes,
schools, hospitals, and drinking-water wells, supported by evidence demonstrating that the distances
are protective of the surrounding community. General guidance, without measurable criteria, is
insufficient. The PEIS should also recommend large-scale fire testing for every facility, regardless of
whether Washington has yet adopted the latest code edition, because Ecology has recognized that such
testing reduces risk.
The PEIS should further make clear that any statewide siting, design, or operational standards establish
minimum requirements only and do not preempt or otherwise restrict a local jurisdiction from imposing
more protective measures when warranted by site-specific conditions. State standards should
therefore operate as a regulatory floor, not a ceiling. In addition, the PEIS should recommend
enforceable, developer-funded obligations for ongoing environmental and safety monitoring, post -
incident investigation and remediation, financial assurances for cleanup, and decommissioning
security, including bonds or equivalent instruments sufficient to ensure that the costs of closure,
removal, restoration, and remediation are borne by the facility owner or operator rather than affected
communities or public agencies. Such financial-assurance measures should be evaluated in light of
analogous requirements applicable to other energy facilities under existing state regulatory programs.
The PEIS should specify the measures necessary to reduce wildfire and emergency-response impacts,
including fully funded training and equipment for local responders before a facility becomes
operational. Where a material impact cannot be reduced to an acceptable level, including a fire beyond
the containment capacity of a small rural fire district, the PEIS should clearly identify that impact as
unavoidable rather than presuming that mitigation will be adequate.
I therefore request that the PEIS identify, at a minimum, the following mitigation requirements:
minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing in
accordance with UL 9540A; compliance with the current edition of NFPA 855 regardless of State
adoption status; funded emergency-response plans, training, and equipment for local fire districts
before operation; containment and lawful disposal plans for contaminated fire-suppression water;enforceable nighttime noise limits measured at the nearest residence; and enforceable
decommissioning and financial-assurance requirements.
Site-Specific Community Considerations
The matters identified above directly affect my household. My residence is located less than one mile
from the proposed site. My children attend Snoqualmie Middle School nearby. In the event of an
emergency, my household would be required to evacuate by way of Snoqualmie Parkway, together with
other residents who depend upon the same roadway.
Because Ecology has stated that stand-alone facilities "could be sited in a variety of locations,"
including locations near cities, the PEIS should not assume that these facilities will be remote from
population centers. Proximity to residents should be treated as a defining condition of environmental
analysis. The Draft PEIS should clearly identify any significant impacts that cannot be reduced below
the applicable significance threshold so that lead agencies and the public are not left to speculate
regarding the nature or severity of unresolved impacts.
Request for Inclusion in the Scoping Record
Thank you for considering this comment. I respectfully request that it be included in the official scoping
record. The affected community is closely following the development of this PEIS and intends to
participate in the public-comment process for the Draft PEIS.
Respectfully submitted,
HENRIKA STICH
36702 SE GRAVENSTEIN CT
SNOQUALMIE WA 98065
206-234-4705
henrika.stich@outlook.com↓
Attachments:
"Suitable" should not simply mean that a site has enough physical space or is close to existing power infrastructure. It should mean that the location is safe and appropriate for the people who already live there, and that the concerns and disapprova...↓l of the surrounding community are meaningfully taken into account.↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Sam Weller and I live at 36708 SE Gravenstein CT, Snoqualmie WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, u...↓tility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
The study should assume facilities would be built to the rules Washington has actually adopted, and say what the newest standards would change, since Ecology admits the state's fire code is behind them. I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the code Washington has actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation.
Q2 · Geographic scope — Where the study assumes batteries will go.
The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. The study should properly model whether neighbors can evacuate without breathing dangerous levels of toxic gas in places such as a valley that traps air, which is what the fire code requires. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live under 1 mile from the proposed site. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Sam Weller
36708 SE Gravenstein CT, Snoqualmie WA 98065↓
My name is Sam Weller and I live at 36708 SE Gravenstein CT, Snoqualmie WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, u...↓tility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
The study should assume facilities would be built to the rules Washington has actually adopted, and say what the newest standards would change, since Ecology admits the state's fire code is behind them. I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the code Washington has actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation.
Q2 · Geographic scope — Where the study assumes batteries will go.
The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. The study should properly model whether neighbors can evacuate without breathing dangerous levels of toxic gas in places such as a valley that traps air, which is what the fire code requires. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live under 1 mile from the proposed site. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Sam Weller
36708 SE Gravenstein CT, Snoqualmie WA 98065↓
No attachments
This movement is wrong and blind sighting. Having such a storage facility without first allowing proper knowledge to the homeowners in the area is wrong. The city and county governments allow for continued growth, but yet the power grid is not secu...↓re. It seems these battery "farms" are the answer but they could be the destruction as well. How about stopping growth for a while. How about not endangering the public. And let's try to focus on what we have at this time and make it work properly!
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To the Department of Ecology, Clean Energy Coordination:
My name is Sarah Carter and I live at 36309 SE Woody Creek Ln, in Snoqualmie, WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, u...↓tility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is very personal for my household. We live under 1 mile from the proposed site, and use the adjacent park and trails daily. In an emergency, my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Sarah Carter
36309 SE Woody Creek Ln, Snoqualmie, WA 98065↓
My name is Sarah Carter and I live at 36309 SE Woody Creek Ln, in Snoqualmie, WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, u...↓tility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is very personal for my household. We live under 1 mile from the proposed site, and use the adjacent park and trails daily. In an emergency, my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Sarah Carter
36309 SE Woody Creek Ln, Snoqualmie, WA 98065↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Winnie Stephenson and I live at 7805 Melrose Ln SE Snoqualmie WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, ...↓utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Ecology promised to hear from local communities and it's important to take what our communities are saying about where we live seriously in order to ensure this study is done properly. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live 1–2 miles from the proposed site. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Winnie Stephenson
7805 Melrose Ln SE Snoqualmie WA 98065↓
My name is Winnie Stephenson and I live at 7805 Melrose Ln SE Snoqualmie WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, ...↓utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Ecology promised to hear from local communities and it's important to take what our communities are saying about where we live seriously in order to ensure this study is done properly. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live 1–2 miles from the proposed site. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Winnie Stephenson
7805 Melrose Ln SE Snoqualmie WA 98065↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Zac Small and I own land at 10393 Halloran Rd in Skagit County. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility...↓-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
For more information on the Samish Island BESS and its flawed installation, visit www.samishislandbess.com
Sincerely,
Zac Small
Home Address 816 Mclean Dr Sedro-Woolley WA
Property Owner: 10393 Halloran Rd. Bow WA 98232↓
My name is Zac Small and I own land at 10393 Halloran Rd in Skagit County. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility...↓-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
For more information on the Samish Island BESS and its flawed installation, visit www.samishislandbess.com
Sincerely,
Zac Small
Home Address 816 Mclean Dr Sedro-Woolley WA
Property Owner: 10393 Halloran Rd. Bow WA 98232↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Jennifer Pierce and I live at 38214 SE 92nd St, Snoqualmie. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scal...↓e, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Snoqualmie Valley's conditions should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live 3 miles from the proposed site and my parents live 1 mile from it. My children go to school nearby, at Snoqualmie Elementary. In an emergency my household would evacuate via I-90, while my parents would have to evacuate via Snoqualmie Parkway along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Jennifer Pierce
38214 SE 92nd St, Snoqualmie↓
My name is Jennifer Pierce and I live at 38214 SE 92nd St, Snoqualmie. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scal...↓e, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Snoqualmie Valley's conditions should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live 3 miles from the proposed site and my parents live 1 mile from it. My children go to school nearby, at Snoqualmie Elementary. In an emergency my household would evacuate via I-90, while my parents would have to evacuate via Snoqualmie Parkway along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Jennifer Pierce
38214 SE 92nd St, Snoqualmie↓
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I am a resident in Sedro Woolley, Wa and I am extremely concerned about the environmental impacts to our already dying farmlands and local food supplies. Additionally, when I was listening to the company during one of the Town Hall meetings a while b...↓ack, they literally said "we will cross that bridge if we get to it" when discussing emergency evacuations for fires and toxic airs. In my opinion, that is insanity that we are still even discussing the potential of these facilities when the company themselves cannot protect the community members or land. We will regret this if we move forward. We will lose salmon, wildlife, food and farmlands. We must stop our precious land from being destroyed.↓
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I am a resident of Snoqualmie Ridge, Washington, and I am writing to raise serious concerns about battery energy storage system (BESS) facilities being sited close to residential neighborhoods, schools, and parks — specifically in reference to the pr...↓oposed Cascadia Ridge Resiliency Energy Storage project near Fisher Creek Park and Snoqualmie Ridge. I urge Ecology to ensure the PEIS thoroughly studies the following:
1. Fire and thermal runaway risk. Lithium-ion BESS fires can burn for hours to days, release toxic gases (including hydrogen fluoride), and are difficult for local fire departments to suppress. The PEIS should require rigorous, enforceable setback distances from homes, schools, and other sensitive receptors based on documented BESS fire incidents nationwide, not industry-proposed minimums.
2. Proximity to schools and residential density. Facilities should not be permitted near schools, daycares, or high-density residential areas without a clear, science-based buffer standard. The scoping should evaluate cumulative risk to nearby populations, including evacuation feasibility.
3. Emergency response capacity. The PEIS should assess whether local fire departments have the specialized training, equipment, and mutual aid agreements needed to respond to a BESS fire, and require project sponsors to fund necessary training and equipment upgrades before permits are issued.
4. Water and soil contamination. Firefighting runoff from a BESS fire can contaminate soil and water. The study should address containment and remediation plans for facilities sited near watersheds and residential wells.
5. Air quality impacts. Off-gassing during a fire or thermal event poses respiratory risks to nearby residents. The PEIS should model worst-case air dispersion scenarios for facilities near populated areas.
6. Property values and quality of life. Noise (from cooling systems), visual impact, and stigma associated with a fire hazard facility can materially affect nearby property values; this should be studied as a socioeconomic impact.
7. Meaningful local input. Because BESS siting decisions may bypass local jurisdictions entirely (as with the shift to EFSEC review for Cascadia Ridge), the PEIS should recommend a formal mechanism ensuring affected cities and residents have real influence over site selection — not just comment opportunities after a site is chosen.
Given the scale of growth expected in BESS deployment statewide, I ask that Ecology adopt precautionary, health-protective standards now, rather than after an incident occurs near a community like mine.
Thank you for considering these comments.↓
1. Fire and thermal runaway risk. Lithium-ion BESS fires can burn for hours to days, release toxic gases (including hydrogen fluoride), and are difficult for local fire departments to suppress. The PEIS should require rigorous, enforceable setback distances from homes, schools, and other sensitive receptors based on documented BESS fire incidents nationwide, not industry-proposed minimums.
2. Proximity to schools and residential density. Facilities should not be permitted near schools, daycares, or high-density residential areas without a clear, science-based buffer standard. The scoping should evaluate cumulative risk to nearby populations, including evacuation feasibility.
3. Emergency response capacity. The PEIS should assess whether local fire departments have the specialized training, equipment, and mutual aid agreements needed to respond to a BESS fire, and require project sponsors to fund necessary training and equipment upgrades before permits are issued.
4. Water and soil contamination. Firefighting runoff from a BESS fire can contaminate soil and water. The study should address containment and remediation plans for facilities sited near watersheds and residential wells.
5. Air quality impacts. Off-gassing during a fire or thermal event poses respiratory risks to nearby residents. The PEIS should model worst-case air dispersion scenarios for facilities near populated areas.
6. Property values and quality of life. Noise (from cooling systems), visual impact, and stigma associated with a fire hazard facility can materially affect nearby property values; this should be studied as a socioeconomic impact.
7. Meaningful local input. Because BESS siting decisions may bypass local jurisdictions entirely (as with the shift to EFSEC review for Cascadia Ridge), the PEIS should recommend a formal mechanism ensuring affected cities and residents have real influence over site selection — not just comment opportunities after a site is chosen.
Given the scale of growth expected in BESS deployment statewide, I ask that Ecology adopt precautionary, health-protective standards now, rather than after an incident occurs near a community like mine.
Thank you for considering these comments.↓
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Why spend all the money and land resources to implement this dangerous BESS.
They say dangers can be mitigated, but no clue how.
Why don't we focus on new energy sources instead.
My property value will suffer if it's anywhere near me.
Most importa...↓ntly, this a serious danger to people and my family!
In the meantime WA is forcing us to use electricity for everything, and the cost is already skyrocketing. There really is no solid evidence that burning natural gas and/or coal causes climate change. It's all scientific "theory".
We say absolutely NO to BESS.
↓
They say dangers can be mitigated, but no clue how.
Why don't we focus on new energy sources instead.
My property value will suffer if it's anywhere near me.
Most importa...↓ntly, this a serious danger to people and my family!
In the meantime WA is forcing us to use electricity for everything, and the cost is already skyrocketing. There really is no solid evidence that burning natural gas and/or coal causes climate change. It's all scientific "theory".
We say absolutely NO to BESS.
↓
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To the Department of Ecology, Clean Energy Coordination:
My name is Jesse Skorupa and I live at 35312 SE Kinsey St. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-i...↓on battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on four questions: what facilities to evaluate, what geographic assumptions to use, what impacts to analyze, and what mitigation to consider. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Being near a substation should not make a place "suitable." I ask that closeness to existing infrastructure not be used as a stand-in for a safe site. Nearly every kind of land is in play, so the study's map has to say where facilities should not go, not only where they could. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
Ecology notes toxic gas from a battery fire can hurt firefighters. Neighbors have no protective gear. I ask that the study model what a battery fire's smoke does to the people living nearby.
Indirect and cumulative effects are in scope. I ask that the study cover smoke that settles into valleys, runoff that reaches wells and streams later, and several facilities on the same stretch of grid. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live under 1 mile from the proposed site. My children go to school nearby, at Cascade View Elementary School. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Jesse Skorupa
35312 SE Kinsey St↓
My name is Jesse Skorupa and I live at 35312 SE Kinsey St. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-i...↓on battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on four questions: what facilities to evaluate, what geographic assumptions to use, what impacts to analyze, and what mitigation to consider. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Being near a substation should not make a place "suitable." I ask that closeness to existing infrastructure not be used as a stand-in for a safe site. Nearly every kind of land is in play, so the study's map has to say where facilities should not go, not only where they could. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
Ecology notes toxic gas from a battery fire can hurt firefighters. Neighbors have no protective gear. I ask that the study model what a battery fire's smoke does to the people living nearby.
Indirect and cumulative effects are in scope. I ask that the study cover smoke that settles into valleys, runoff that reaches wells and streams later, and several facilities on the same stretch of grid. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live under 1 mile from the proposed site. My children go to school nearby, at Cascade View Elementary School. In an emergency my household would evacuate via Snoqualmie Parkway, along with everyone else who depends on that road.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Jesse Skorupa
35312 SE Kinsey St↓
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Due to the potential environmental and citizen impacts these sites need to be a minimum of 50 miles from any densely populated areas. Financial impacts need to fall on the utilities installing these facilities. Failure in one site has far reaching...↓ negative impacts to biological inhabitants. Smaller distances cannot be allowed in any site in Washington state. Anything less the 50-mile limit puts the state and citizens at great risk of which the state will be liable. If one were to be sited closer than this to my community, the community would sue the state.↓
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I am a resident of Snoqualmie. I am horrified of the thought of an ugly and unsafe battery storage facility in my neighborhood. We literally live in one of the most beautiful and visited places in the state and showcase an amazing waterfall, cute dow...↓ntown, train, trails, a river, and a casino. Now they want to ruin it. Literally ruin it by throwing an ugly, dangerous, toxic, and noisy BESS in the middle of it. Awful people! If it must be built, and I do not believe it does, then do it away from schools and families and tourists attractions that feature the best of this beautiful state.↓
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So a lithium battery powered golf cart exploded with no warning on the Willows run golf course in Redmond last week. Yet people think it a good idea to build a facility on Snoqualmie ridge the windiest place in King County. I think its clear this is ...↓not a safe power alternative↓
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I appreciate the analysis and clarity of the scoping document. I hope you will additionally consider aspects of environmental justice for other marginalized communities who are impacted by displacement. Your point about the dominance and increasing s...↓afety of lithium ion batteries is valid, but I think you should also consider the new chemistries being deployed for safety and cost as part of the mix. Please also consider the longer term environmental benefits that BESS may provide by reducing the need for carbon emitting power sources.↓
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Hello,
My readings on utility battery storage lead me to see it as an essential part of the energy strategy.
Going back to Tesla's installation in Australia, the electric utility reported significant improvements in power management from millisecon...↓d-level peaking responses.
There are risks, like lithium-ion fires, but they're known, preventable, and have proven mitigations.
I see mostly positives and few, manageable negatives in BESS.
↓
My readings on utility battery storage lead me to see it as an essential part of the energy strategy.
Going back to Tesla's installation in Australia, the electric utility reported significant improvements in power management from millisecon...↓d-level peaking responses.
There are risks, like lithium-ion fires, but they're known, preventable, and have proven mitigations.
I see mostly positives and few, manageable negatives in BESS.
↓
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While I support solar as an energy source the risks of lithium battery storage in our area seem problematic due to proximity to clean water and soil intended to grow food. What is the clearance from these zones? Once it's gone it's GONE. I think it's...↓ safe to say a spill WILL happen so what is the safety protocol...? We have volunteer run fire departments-will they be trained to help? There is a lot of tribal land, the residents there should have a say in these BESS locations. The whole thing makes me rather nervous. I was in CA during the Moss Landing incident-very scary! Please keep human health in the forefront of your decision making. In addition as a component, perhaps we can address using LESS energy in general: lights out at night as a strong message to our surrounding cities & will also lend to our migratory and resident bird population, something this area is well known for.↓
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I urge you to look into the entire impact of BESS - to our environment, our children, how it's managed when there are problems, our support infrastructure, etc
Please, if we must have them. Let's limit them to highly industrialized areas and a long ...↓ways away from our communities.↓
Please, if we must have them. Let's limit them to highly industrialized areas and a long ...↓ways away from our communities.↓
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Please do not allow these Lithium Battery projects on Farmland, Residential area, near schools, Hospitals or heavy populated areas
They are expecting our Fire Dept to manage and handle all emergencies. . Our local FD are made up of all volunteer ind...↓ividuals. 3 actual employed Fire employees. Our community would not have enough time to evacuate when there is an emergency. Too much danger for our waterways.
Build them only in Heavy industrial zoned land and away from all the above.
Think of the citizens↓
They are expecting our Fire Dept to manage and handle all emergencies. . Our local FD are made up of all volunteer ind...↓ividuals. 3 actual employed Fire employees. Our community would not have enough time to evacuate when there is an emergency. Too much danger for our waterways.
Build them only in Heavy industrial zoned land and away from all the above.
Think of the citizens↓
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I'm for green energy to combat climate change and if BESS is the right solution for that, I'm on board. However, we need to be careful, thoughtful, and intentional with the placement of these batteries.
They belong in commercial areas where fire de...↓partments are prepared and equipped to handle any situation. I'm deeply concerned about these going near schools, residential areas, and natural lands prone to wildfire.
Please keep these away from heavily populated areas. Transmission lines are feasible options to properly locate BESS and extend their reach.
Thank you,
Tyler Grove↓
They belong in commercial areas where fire de...↓partments are prepared and equipped to handle any situation. I'm deeply concerned about these going near schools, residential areas, and natural lands prone to wildfire.
Please keep these away from heavily populated areas. Transmission lines are feasible options to properly locate BESS and extend their reach.
Thank you,
Tyler Grove↓
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I do believe these BESS would be great benefit for the State of Washington to offset the Greenhouse Gas Emissions and to cut our reliance on fossil fuel. I understand there are concern with BESS with solar and wind; however, since majority of our el...↓ectric power is hydroelectric, is there a safety issue in combining hydroelectric with BESS?
I do believe BESS would be great for those isolated locations and during off-peak seasons (Summer for those with hydroelectric, Winter for those with solar) and help keep the electric bill down.↓
I do believe BESS would be great for those isolated locations and during off-peak seasons (Summer for those with hydroelectric, Winter for those with solar) and help keep the electric bill down.↓
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1. "What is the site-specific thermal runaway and fire response plan, and has the local fire department reviewed and signed off on it?" Unless you are using the latest Sodium Ion batteries, Lithium ion has been known to be problematic.
2. "What are...↓ the decommissioning and end-of-life battery disposal/recycling obligations, and is there a bonded financial guarantee behind them?"
3. "What cumulative impact analysis was done for water resources and groundwater — specifically fire suppression runoff and any chemical leaching, not just routine operations?"↓
2. "What are...↓ the decommissioning and end-of-life battery disposal/recycling obligations, and is there a bonded financial guarantee behind them?"
3. "What cumulative impact analysis was done for water resources and groundwater — specifically fire suppression runoff and any chemical leaching, not just routine operations?"↓
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I support Ecology's study of utility-scale battery energy storage systems. Battery storage is an important part of Washington's energy future because it can store electricity when generation is abundant and provide power when demand is high. This fle...↓xibility can help integrate wind and solar energy, improve grid reliability, reduce dependence on fossil-fuel generation, and support a more resilient electric system.
A programmatic review will help the state plan for battery storage consistently and efficiently while providing clear information to communities, utilities, local governments, and project developers. By evaluating battery storage at a statewide level, the Department can identify best practices for siting, construction, operation, emergency preparedness, and decommissioning. This approach can help ensure that future projects are developed responsibly while avoiding unnecessary administrative delays and supporting investments in energy and infrastructure.
Battery energy storage can also provide broad public benefits, including improved energy security, greater grid flexibility, reduced greenhouse-gas emissions, and support for critical facilities during outages or emergencies. I encourage Ecology to move forward with the PEIS and to use it to establish a clear framework that enables the expansion of battery storage across Washington.↓
A programmatic review will help the state plan for battery storage consistently and efficiently while providing clear information to communities, utilities, local governments, and project developers. By evaluating battery storage at a statewide level, the Department can identify best practices for siting, construction, operation, emergency preparedness, and decommissioning. This approach can help ensure that future projects are developed responsibly while avoiding unnecessary administrative delays and supporting investments in energy and infrastructure.
Battery energy storage can also provide broad public benefits, including improved energy security, greater grid flexibility, reduced greenhouse-gas emissions, and support for critical facilities during outages or emergencies. I encourage Ecology to move forward with the PEIS and to use it to establish a clear framework that enables the expansion of battery storage across Washington.↓
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Comment From: Centre for Studies and Experim... (Manuel Ramón García Sánchez-Colomer)
9/02/26 @ 11:02 PM
Good morning from Spain,
I conducted a search using Copilot with the following prompt:
"I need you to search BOE.es for environmental impact assessment documents related to battery energy storage projects."
The response was:
"I have identified seve...↓ral environmental assessment proceedings published in the Spanish Official State Gazette (BOE) related to Battery Energy Storage Systems (BESS). These are particularly relevant because many of them include the environmental document, impact assessments, consultations with public authorities, and proposed mitigation and corrective measures."
In the attached document, I have included links to the projects, which can be easily translated using any online translation tool.
If you encounter any issues or have any questions, please do not hesitate to contact me.
Kind regards,
Manuel Ramón García Sánchez-Colomer, PhD
Área de Ingeniería Ambiental / Environmental Engineering Department
Centro de Estudios y Experimentación de Obras Públicas (CEDEX) / Centre for Studies and Experimentation of Public Works (CEDEX)
Tel. (+34) 91 335 72 01
manuel.colomer@cedex.es
C/ Alfonso XII, 3 - 28014 Madrid (España)
www.cedex.es↓
I conducted a search using Copilot with the following prompt:
"I need you to search BOE.es for environmental impact assessment documents related to battery energy storage projects."
The response was:
"I have identified seve...↓ral environmental assessment proceedings published in the Spanish Official State Gazette (BOE) related to Battery Energy Storage Systems (BESS). These are particularly relevant because many of them include the environmental document, impact assessments, consultations with public authorities, and proposed mitigation and corrective measures."
In the attached document, I have included links to the projects, which can be easily translated using any online translation tool.
If you encounter any issues or have any questions, please do not hesitate to contact me.
Kind regards,
Manuel Ramón García Sánchez-Colomer, PhD
Área de Ingeniería Ambiental / Environmental Engineering Department
Centro de Estudios y Experimentación de Obras Públicas (CEDEX) / Centre for Studies and Experimentation of Public Works (CEDEX)
Tel. (+34) 91 335 72 01
manuel.colomer@cedex.es
C/ Alfonso XII, 3 - 28014 Madrid (España)
www.cedex.es↓
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